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119-hr-10682119th CongressWALLET

To amend the Internal Revenue Code of 1986 to provide parity in the taxation of professional sports franchises under the limitation on the deduction for certain employee remuneration, and for other purposes.

Sponsored By: Representative Malliotakis, Nicole [R-NY-11]

Introduced

Summary

Excludes pay for athletes from the Section 162(m) top-five compensation deduction cap. This bill would change who counts as an employer's five highest compensated employees so that individuals who perform services in athletics are not included when applying the deduction limit.

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  • Professional athletes and athletics staff: Employers could deduct larger amounts of remuneration paid to athletes and other athletics personnel because that pay would not count toward the top-five cap.
  • Sports franchises and team owners: Teams could claim bigger compensation deductions tied to athletic pay, shifting tax treatment in favor of athletics compensation compared with other high-paid employees.
  • Other covered executives: The bill preserves existing 162(m) limits for the employee categories already listed in subparagraphs (A) and (B) and makes a technical cross-reference fix to 162(m)(3)(D).
  • Timing and definition: The change applies to taxable years beginning after December 31, 2026, so it would take effect for tax years starting in 2027. The athletics exclusion relies on the definition in 26 CFR 1.199A-5(b)(2)(viii) as in effect on enactment.

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Bill Overview

Analyzed Economic Effects

1 provisions identified: 1 benefits, 0 costs, 0 mixed.

More deductible pay for sports teams

If enacted, the bill would let sports teams leave athletics workers out of the five highest-paid employee test. That test determines whether pay is limited under Section 162(m). Pay to athletics workers would not be subject to the top-five deduction cap. The change would apply to tax years starting after December 31, 2026. The bill also makes a technical wording fix to a cross-reference.

Sponsors & CoSponsors

Sponsor

Malliotakis, Nicole [R-NY-11]

NY • R

Cosponsors

  • Rep. Suozzi, Thomas R. [D-NY-3]

    NY • D

    Sponsored 10/1/2026

  • Rep. Jack, Brian [R-GA-3]

    GA • R

    Sponsored 10/1/2026

  • Rep. McBath, Lucy [D-GA-6]

    GA • D

    Sponsored 10/1/2026

  • Rep. Fuller, Clay [R-GA-14]

    GA • R

    Sponsored 10/5/2026

  • Rep. Garbarino, Andrew R. [R-NY-2]

    NY • R

    Sponsored 10/29/2026

  • Rep. Scott, Austin [R-GA-8]

    GA • R

    Sponsored 10/15/2026

  • Rep. Williams, Nikema [D-GA-5]

    GA • D

    Sponsored 10/29/2026

  • Rep. Carter, Earl L. "Buddy" [R-GA-1]

    GA • R

    Sponsored 10/22/2026

  • Rep. Loudermilk, Barry [R-GA-11]

    GA • R

    Sponsored 10/26/2026

Roll Call Votes

No roll call votes available for this bill.

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