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Super Bowl players are subject to Duty Days, a source of revenue for 21 states when non-resident professional athletes play for pay BUT California has unique parameters
A conversation is circling around various bloggers scripts and even network sport announcer are talking about the huge hit the players are taking, using Sam Darnold's deficit paycheck as an example. An extensive article was written by Tax Notes in 2024: Drawing the Line: Professional Athletes for State Tax Purposes Including clarifying the tax bite: California "has a generic set of rules that gross income derived from games in the state must be reported in the state by non-California residents, without having a specific duty-days-based apportionment formula"
Title 18 - Public Revenues Division 3 - Franchise Tax Board Chapter 2.5
Services Performed in this State
California Code of Regulations
Title 18. Public Revenues
Division 3. Franchise Tax Board
Chapter 2.5. Personal Income Tax (Taxable Years Beginning After 12-31-54) (Refs & Annos)
Subchapter 11. Gross Income of Nonresidents
Cal. Code Regs. Tit. 18, §§ 17951-5 - Wages, Salaries and Other Compensation for Personal
Actually Cal. Code Regs. section 17951-5(a)(2) also applies to the non-resident performers during the infamous Half-Time Show: Big Bunny, Lady Gaga, and Cardi B, (Ricky Martin, Karol G & Pedro Pascal have homes in Los Angeles but may be considered non-residents)
Which originated in California's market-based sourcing rules in effect since the passing of Proposition 39 in 2012. Proposition 39 | Official Voter Information Guide | California Secretary of State text-proposed-laws-v2.pdf
Who performed at the Super Bowl halftime show? See the full list
The revision in Sept 2024: Request to Proceed to Adopt Amendments to CA Code of Regulations, TITLE 18, SECTION 17951-8.
BUT THE ACTUAL DETAILS ARE VERY HARD TO ASCERTAIN!
"The Code of Federal Regulations (CFR) annual edition is the codification of the general and permanent rules published in the Federal Register by the departments and agencies of the Federal Government. It is divided into 50 titles that represent broad areas subject to Federal regulation.
The 50 subject matter titles contain one or more individual volumes, which are updated once each calendar year, on a staggered basis.
- The annual update cycle is as follows:
- titles 1-16 are revised as of January 1;
- titles 17-27 are revised as of April 1; *
- titles 28-41 are revised as of July 1;
- titles 42-50 are revised as of October 1.
- Each title is divided into chapters, which usually bear the name of the issuing agency.
- Each chapter is further subdivided into parts that cover specific regulatory areas.
- Large parts may be subdivided into subparts. All parts are organized in sections, and most citations to the CFR refer to material at the section level." Read More.
So, for 2025 the revision in Sept 2024: Request to Proceed to Adopt Amendments to CA Code of Regulations, TITLE 18, SECTION 17951-8.
EDIT: Added image and caption
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