Manning Retires with Two Last Victories

Peyton Manning is going out in style with two last wins. One over the Carolina Panthers in the Super Bowl and the other over the California Tax Board.

Situation:

This past off-season, Peyton Manning restructured his contract and converted a portion of his base salary into $4,000,000 in performance bonuses.  By winning the Conference Championship ($2,000,000) and Super Bowl ($2,000,000), Peyton Manning earned an additional $4,000,000 in bonuses, in addition to the earnings all players earn in the playoffs, Manning’s total on-field earnings from football in 2016 are $4,173,000.

In general, Manning’s bonus would be considered income, added to his 2016 earnings and allocated to all states in which he performed services during the season.  However, with Manning retiring, his 2016 football earnings will present a unique situation.

Tax Implications:

Manning’s total football earnings in 2016 will need to be allocated into every tax jurisdiction where Manning plays during the tax year. The allocation will be based off the number of days (duty days) spent in each jurisdiction divided by the total number of days Manning performed services for the Broncos, which would usually include not only the season but also training camp, playoffs and all mandatory offseason training.

With the Super Bowl being Manning’s last game, he will have been employed by the Broncos for only 38 total days in 2016.  As a resident of Colorado, Manning will have to claim his entire income in the state and will be able to claim a partial credit for taxes paid to other states. 

Since his income was also earned with his victory in the Super Bowl, a portion of his total earnings will be apportioned into California (seven days out of 38). This is due to the fact that performance bonuses, contingent on services performed, are allocated to every state in which an athlete plays. Manning’s last football earning apportionment and his taxes paid is shown in the chart below.

Manning retirement chart

It should be noted that even though Manning earned $2,102,000 in California by winning the Super Bowl ($2,000,000 bonus plus $102,000 winning team earnings), only $768,710.53 will be allocated to California and he will only owe $89,381 to California taxes.

This means his marginal tax rate on what Manning “earned” in California ($2,102,000) is a mere 4.25%. This is a far cry from Cam Newton’s California marginal tax rate after the Super Bowl, which will be a whopping 103.36% (for more on Newton see: http://http://afptax.com/news/newton/)

If Manning plays 2016:

With Manning announcing his retirement, it seems highly unlikely he will suit up again next season. However, the possibility cannot entirely be ruled out as Brett Favre returned multiple times after retiring.

If Manning does play an additional season, the $4,173,000 Manning earned in the playoffs with the Broncos will be allocated along with whatever he earns next season, regardless of where he plays. The allocation will be based off of his new team’s 2016 road schedule and also include the allocation above, with a change in the number of total days, depending on how many days he may spend with a team next season.

Conclusion:

Manning’s playoff bonuses and his potential retirement make his tax situation unique. If Manning does indeed hang up his cleats, he will have earned $4,173,000 allocated over only 38 days, something very few football players have done/will do.

 If Manning retires, he obviously will have other income in 2016, but it not be allocated in the same manner as his playoff earnings. This is just another example of every athlete having a similar yet unique tax situation that requires professional expertise.

ALAN POGROSZEWSKI is an Associate Professor of Sports Studies at St. John Fisher College and the President of his own tax consulting business whose clientele include professional athletes performing services on three separate continents. Prior to accepting his position at St. John Fisher College, Mr. Pogroszewski was the Vice President of Business Operations for Sports Consulting Group, a firm that specializes in the representation of professional hockey players. Mr. Pogroszewski received his M.B.A. from Rochester Institute of Technology in 1996 and his M.S. in Taxation from St. John Fisher in 2003

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