When Shohei Ohtani emigrated to the United States from Japan in 2018 to play in Major League Baseball (MLB), he was widely considered one of the most touted baseball prospects ever.1[1]Jonathan Mayo, No two ways about it: Ohtani one of a kind, MLB (Dec. 1, 2017), https://www.mlb.com/news/scouting-report-on-japanese-star-shohei-ohtani-c254954096#:~:text=The%20Ohtani%20scouting%20report&text=He’s%20been%20up%20to%20102,foot%2D5%20frame%20and%20delivery. Not only could Ohtani hit and pitch, but he could do both at elite levels. After signing with the Los Angeles Angels, Ohtani justified the hype surrounding himself, winning Rookie of the Year, two MVP awards, and consistently putting up pitching statistics that had him in the running for the American League’s Cy Young, a yearly award for the best pitcher.2[2]MLB Baseball, Players, Awards (March 20, 2025), https://www.mlb.com/player/shohei-ohtani-660271?stats=career-r-hitting-mlb&year=2025.
In 2023, Ohtani signed an unprecedented contract with the Los Angeles Dodgers that will pay him $700 million for a 10-year commitment to the team, with most of the salary deferred to a subsequent 10-year period. This paper will break down that contract and explain how MLB players get paid and pay taxes, evaluate the history of deferred contracts in professional sports, and explore why opting for a deferred payment structure is beneficial to professional athletes. Finally, it will explain California’s legislative response to the Shohei Ohtani contract and how they are combatting the deferred payment strategy.
Shohei Ohtani’s Contract
Shohei Ohtani’s free agency process in the winter of 2023 was uncharted territory, as a player of his caliber had never hit the open market before.3[3]Gabe Lacques, Shohei Ohtani is MLB’s best free agent ever. Will MVP get $500 million even with injury?, USA Today (Nov. 11, 2023), https://www.usatoday.com/story/sports/mlb/columnist/gabe-lacques/2023/11/11/shohei-ohtani-free-agent-mlb-contract/71534553007/. A team able to pry him away from the Angels would not only get a hall-of-fame caliber player at two different positions, but arguably the sport’s biggest superstar in several decades. When Ohtani ultimately decided to sign with the Los Angeles Dodgers on December 11, 2023, the contract he signed was atypical within the sporting world.4[4]Nathan Goldman & Christina Lewellen, Inside Shohei Ohtani’s Unusual Contract, Pool Thought Leadership (Sep. 23, 2024), https://poole.ncsu.edu/thought-leadership/article/inside-shoehei-ohtanis-unusual-contract/#:~:text=Ohtani’s%20contract%20includes%20an%20extremely,91%20million%20by%20deferring%20payment. Not only was the ten-year, $700 million contract the largest in American sports history, but for the first ten years of the contract, from 2024 to 2033, Ohtani would only be making $2 million a year.5[5]Teddy Ricketson, Shohei Ohtani contract, explained: Breaking down salary, length, and deferrals in Dodgers star’s unique $700M deal, Sporting News (Oct. 5, 2024), https://www.sportingnews.com/us/mlb/los-angeles-dodgers/news/shohei-ohtani-contract-salary-length-deferrals-dodgers/9215d71aaa6d05cd4345ddd4. However, after 2033, Ohtani will then make $68 million a year for an additional ten years.6[6]Id. While deferred contracts are not new in baseball, one of this magnitude is unprecedented.7[7]Nathan Goldman & Christina Lewellen, Inside Shohei Ohtani’s Unusual Contract, Pool Thought Leadership (Sep. 23, 2024), https://poole.ncsu.edu/thought-leadership/article/inside-shoehei-ohtanis-unusual-contract/#:~:text=Ohtani’s%20contract%20includes%20an%20extremely,91%20million%20by%20deferring%20payment.
Ohtani’s deferred contract structure offers benefits for both parties. For the Dodgers, deferring a large portion of Ohtani’s contract until next decade reduces their current annual payroll and frees up resources to sign other elite players.8[8]Dan Freedman, A Deep Dive Into Deferred Contract From The 1950s To Today, Forbes (Dec. 14, 2022), https://www.forbes.com/sites/danfreedman/2024/12/12/a-deep-dive-into-deferred-contracts-from-the-1950s-to-today/. The “Play Now, Pay Later” strategy is clearly favored by the front office and the fans, as the Dodgers won the World Series last season using this pay model and—after an offseason of signing multiple all-star players to deferred contracts—come into the 2025 MLB season as favorites to repeat.9[9]ESPN, 2025 World Series Odds: Dodgers, Yankees, Mets enter spring as favorites, (Feb. 10, 2025), https://www.espn.com/sports-betting/story/_/id/38801876/2025-world-series-odds-mlb-baseball. The Dodgers now owe over $1 billion to seven different players from 2028 to 2046.10[10]Associated Press, Dodgers’ deferred payments top $1 billion to 7 players, ESPN (Dec. 3, 2024), https://www.espn.com/mlb/story/_/id/42760649/dodgers-deferred-payments-top-1-billion-7-players.
For Ohtani and the other players who signed deferred contracts, the benefit is not as straightforward as winning championships. Playing in California, Ohtani and his fellow teammates face one of the highest state income tax rates in the country.11[11]Andrey Yushkov, State Individual Income Tax Rates and Brackets, 2024, Tax Foundation (Feb. 20, 2024), https://taxfoundation.org/data/all/state/state-income-tax-rates-2024/. However, Ohtani and others do not begin paying taxes on their deferred payments until they start receiving them next decade.12[12]Julia Kagan, Tax Deferred: Earnings With Taxes Delayed Until Liquidation, Investopedia (Mar. 13, 2025), https://www.investopedia.com/terms/t/taxdeferred.asp#:~:text=Tax%2Ddeferred%20refers%20to%20income,typically%20done%20in%20the%20future. This flexibility could potentially save them—and deprive California—of tens of millions of dollars in taxes.
How MLB Players get Paid and Pay Taxes
Professional athletes’ lucrative contracts are more complex than the headlines suggest. The contracts often contain multiple forms of payment such as incentives, endorsement deals, or bonuses that may be paid out at different points throughout the deal.13[13]How Do MLB Players Get Paid? Exploring Their Salary Structures, Baseball Gain (Aug. 30, 2024), https://baseballgain.com/how-do-mlb-players-get-paid/ However, the bulk of the contract is typically structured like an average worker’s salary—albeit for a much larger sum of money.14[14]Id. Because the services rendered by these players only occur for a portion of the year, MLB players only get paid during the regular season—April to September—and not the offseason.15[15]Id. This can be a stressful pay structure for players who are on lower level contracts.
What is an even bigger headache for players, and presumably their accountants, is figuring out the taxes they need to pay. In addition to state and federal taxes, MLB players also pay what is known as a “jock tax.”16[16]Breaking Down the “Jock Tax”, H&R Block, https://www.hrblock.com/tax-center/income/wages/the-jock-tax/?srsltid=AfmBOorR_pURBLzAcGCcXxKPKF5hMeMXWwyOS1kXPo0jB8b7cqMIqW3D. States with jock taxes—nearly every state and large municipality with a professional sports team—tax nonresident athletes’ income earned while playing in the state.17[17]Id. The jock tax was first introduced in the 1960’s but became famous in the 1990’s when Michael Jordan and the Chicago Bulls defeated the Los Angeles Lakers in the 1991 NBA Championship.18[18]Colin Salao, How Michael Jordan’s ‘Jock Tax’ Brought Millions to State Budgets, The Street (Apr. 22, 2023), https://www.thestreet.com/sports/how-michael-jordans-jock-tax-brought-millions-to-state-budgets Jordan and his teammates were notified they would have to pay California state income taxes for the games played in Los Angeles.19[19]Id. For MLB players, that means state taxes have to be filed and paid in every state they play in that has a jock tax.20[20]Breaking Down the “Jock Tax”, H&R Block, https://www.hrblock.com/tax-center/income/wages/the-jock-tax/?srsltid=AfmBOorR_pURBLzAcGCcXxKPKF5hMeMXWwyOS1kXPo0jB8b7cqMIqW3D. For Ohtani and his Dodgers teammates, almost three-quarters of their yearly income tax goes to California because of their home games and other opponents they play within the state.21[21]MLB Baseball, Los Angeles Dodgers, 2024 Schedule (https://www.mlb.com/dodgers/schedule/2024-04).
History of Deferred Contracts
The original concept of the deferred contract in sports came from Ralph Dolgoff, an accountant for the American Basketball Association (ABA).22[22]Dan Freedman, A Deep Dive Into Deferred Contract From The 1950s To Today, Forbes (Dec. 14, 2022), https://www.forbes.com/sites/danfreedman/2024/12/12/a-deep-dive-into-deferred-contracts-from-the-1950s-to-today/. In the late 1970’s, the ABA was struggling to compete with the NBA, when Dolgoff introduced the “Dolgoff Plan.”23[23]Id. As a part of this plan, the ABA offered players lucrative and large contracts compared to the NBA, but with the payments spread out over a 10 to 20 year period.24[24]Id. At the time, the ABA was viewed as the first league to start throwing around “big money.”25[25]Id. But in reality, the money wasn’t big, just long-term annuities that looked big at face value.26[26]Id.
The Dolgoff Plan made its way to MLB in the 1980’s, originally as a form of retirement benefits.27[27]Michael Mayer, MLB Matters: Understanding Deferred Money Contracts, Metsmerized Online, Jul. 1, 2020, https://metsmerizedonline.com/understanding-deferred-money-contracts/. Teams began structuring contracts with their most well-known players to offer payments for years after they retired.28[28]Id. At the turn of the 21st century, free agent players were commanding massive hundred-million-dollar contracts and the only way for teams to mitigate the risk and allow themselves a chance to field a competitive team was to defer significant portions of the contract 10 to 20 years down the line.29[29] Dan Freedman, A Deep Dive Into Deferred Contract From The 1950s To Today, Forbes, Dec. 14, 2022, https://www.forbes.com/sites/danfreedman/2024/12/12/a-deep-dive-into-deferred-contracts-from-the-1950s-to-today/. As the years went on and the contracts grew larger, the deferred payments became even more commonplace.30[30]Id. All of this culminated in Shohei Ohtani signing his ten-year, $700 million contract—$680 million of which is deferred.31[31]Teddy Ricketson, Shohei Ohtani contract, explained: Breaking down salary, length, and deferrals in Dodgers star’s unique $700M deal, Sporting News, Oct. 5, 2024, https://www.sportingnews.com/us/mlb/los-angeles-dodgers/news/shohei-ohtani-contract-salary-length-deferrals-dodgers/9215d71aaa6d05cd4345ddd4.
Benefits and Detriments of a Deferred Contract
While Ohtani’s deal does provide great flexibility for his team—allowing them to go out and sign more players and give them the best chance to win championships—there is speculation that the tax benefits are an additional motivating factor.32[32]Mihael Mccan, et. al., Ohtani’s $680M Deferment Hits Interest Income To Save on Taxes, Sportico, Dec. 12, 2023, https://www.sportico.com/law/analysis/2023/ohtani-interest-free-deferred-money-tax-1234756781/. At a 13.3% income tax rate for its highest earners, California has one of the largest income tax rates in the country.33[33]Andrey Yushkov, State Individual Income Tax Rates and Brackets, 2024, Tax Foundation, Feb. 20, 2024, https://taxfoundation.org/data/all/state/state-income-tax-rates-2024/. According to a study by the California Center for Jobs & the Economy, Ohtani will save potentially $98 million in taxes over the life of his contract.34[34]California strikes out on Ohtani’s blockbuster Dodger deal Tax analysis of Shohei Ohtani’s Salary Deferral, California Center for Jobs & the Economy, https://centerforjobs.org/wp-content/uploads/Ohtani-Tax-Analysis-FINAL.pdf. This amounts to almost $10 million a year in state income taxes.35[35]Id.
While the structure of deferred contracts pays major dividends for MLB teams and the players, it has already become a major detriment to the states that lose out on the tax revenue.36[36]Mihael Mccan, et. al., Ohtani’s $680M Deferment Hits Interest Income To Save on Taxes, Sportico (Dec. 12, 2023), https://www.sportico.com/law/analysis/2023/ohtani-interest-free-deferred-money-tax-1234756781/. California specifically suffers because the state’s budget revenue depends heavily on high income taxpayers like Ohtani.37[37]George Skelton, Column: California’s budget relies on the richest taxpayers, and we’re paying the price, Los Angeles Times (Apr. 22, 2024), https://www.latimes.com/california/story/2024-04-22/column-californias-budget-relies-on-the-richest-taxpayers-and-were-paying-the-price. In 2021, taxpayers with adjusted gross income (AGI) of $200,000 or more comprised only 9.8% of all tax returns but paid 81.1% of the total personal income tax.38[38]California strikes out on Ohtani’s blockbuster Dodger deal Tax analysis of Shohei Ohtani’s Salary Deferral, California Center for Jobs & the Economy, https://centerforjobs.org/wp-content/uploads/Ohtani-Tax-Analysis-FINAL.pdf. Furthermore, ultra-high income earners—having an AGI of $10 million or more—constituted only 0.05% of the tax returns but accounted for 24.4% of total income tax revenue.39[39]Id. If Ohtani changes his residence in 2033 when the payments of $68 million a year begin, he could be depriving California of yearly tax revenue equivalent to the bottom 1,780,000 tax filers in the state.40[40]Id.
At the moment, there is not much California can do. Article XVI of the current MLB Collective Bargaining Agreement states, “[t]here shall be no limitations on either the amount of deferred compensation or the percentage of total compensation attributable to deferred compensation for which a Uniform Player’s Contract may provide.”41[41]Major League Baseball Collective Bargaining Agreement, MLB Players Ass’n, 2022, https://www.mlbplayers.com/_files/ugd/4d23dc_d6dfc2344d2042de973e37de62484da5.pdf. Further, Title 4, Section 114 of the Internal Revenue Code does not allow a State to “impose an income tax on any retirement income of an individual who is not a resident of such State,”42[42]State Taxation of Pension Income Act, 4 U.S.C. § 114(a) (amended 2006). including “an eligible deferred compensation plan.”43[43]Id. at § 114(d) (2006).
California’s Legislative Response
The California legislature, however, is not going down without a fight. Less than a month after Ohtani’s signing, Malia M. Cohen, the State Controller for California, released an official statement urging federal lawmakers to consider reforms within the U.S. tax policy.44[44]Debra Tortorelli, Controller Cohen: Statement Regarding Ohtani Contract, California State Controller’s Officer PR24:01 (Jan. 8, 2024), https://www.sco.ca.gov/eo_pressrel_25445.html. Cohen notes that Ohtani “could potentially return to Japan and escape payment of California state income taxes on the deferred amount” and that without any reforms to the deferred contract structure, wealthy individuals will continue to further “exacerbate income inequality and hinder the fair distribution of taxes.”45[45]Id.
On April 15, 2024, the California State Senate passed SJR-14, a joint resolution that urges Congress to curtail deferred compensation agreements.46[46]California Legislature – 2023-2024 Regular Session, SJR-14 Deferred compensation (Mar. 4, 2024), https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=202320240SJR14. The bill directly references Ohtani’s contract and its potential effects of creating an unbalanced and unequal tax system.47[47]Id. When asked about the implications of Ohtani’s contract on California tax revenue, Senator Josh Becker, author of the bill stated, “[i]t is disturbing that Shohei Ohtani and other individuals can perform a hidden ball trick using an obscure tax loophole to avoid paying hundreds of millions of dollars and it’s a concerning precedent.”48[48]Paul Jones, California Proposal Would Urge Congress to Block Ohtani-Type Deferred Pay, Tax Notes (Apr. 18, 2024), https://www.taxnotes.com/featured-news/california-proposal-would-urge-congress-block-ohtani-type-deferred-pay/2024/04/17/7jfhp. Becker went on to describe how this situation goes beyond Ohtani and how we need to focus on “a precedent that allows high-income earners to start paying their fair share.”49[49]Id. Lastly, Becker adds that the “deferred compensation was meant for small amounts of income, for pension income,” not for these ultra-high income earning athletes to avoid state taxes.50[50]Id.
While SJR-14 passed through the California State Senate with a lot of support, there were still many critics who espoused how their fellow legislative members were focusing on the wrong problem. The biggest dissenter of the bill, Senator Kelly Seyarto, argued that the real problem was in California’s own backyard and something the State Senate could have direct control over.51[51]Id. Seyarto pointed to California’s extremely high tax rate as the main issue and stated that, “[t]he reason that a ballplayer such as Mr. Ohtani would defer [a majority of his contract] is because it costs so dang much, and our taxes are so high, that they have to come up with creative means of doing their salary.”52[52]Id. Senator Seyarto urged his fellow lawmakers to make California’s tax rates more competitive and warned that continuing this push to gather more taxes from athletes could only drive them away to teams in lower-tax states.53[53]Id. He urged everyone to consider “why people would have to go through all of these creative means to protect some of the money they make.”54[54]Id. In response, Senator Becker brought the conversation back to fairness and setting a reasonable precedent.55[55]Id.
Conclusion
As another offseason is in the books and the MLB season is set to start again, the time for players and agents to negotiate contract terms is put on pause, but the topic of deferred contract structures will only continue to loom and gain notoriety. And when these negotiations continue next winter, other discussions will take place simultaneously, between State legislators like Senator Becker and Senator Seyarto on California’s stance on these deferred contracts. It’s hard to tell what Congress’s interpretation of the policy will be. Will they side with Senator Becker and California and put the plans in place to start a precedent of fairness? Or will they see Ohtani’s contract the same as many others have, as an anomaly? No matter which way they view this issue, the debate surrounding deferred contract structures and whether there should be any limitations placed on them is not going away any time soon.
Written by: Charles Cariello
Charles is a 2027 J.D. Candidate at Brooklyn Law School.
[1] Jonathan Mayo, No two ways about it: Ohtani one of a kind, MLB (Dec. 1, 2017), https://www.mlb.com/news/scouting-report-on-japanese-star-shohei-ohtani-c254954096#:~:text=The%20Ohtani%20scouting%20report&text=He’s%20been%20up%20to%20102,foot%2D5%20frame%20and%20delivery.
[2] MLB Baseball, Players, Awards (March 20, 2025), https://www.mlb.com/player/shohei-ohtani-660271?stats=career-r-hitting-mlb&year=2025.
[3] Gabe Lacques, Shohei Ohtani is MLB’s best free agent ever. Will MVP get $500 million even with injury?, USA Today (Nov. 11, 2023), https://www.usatoday.com/story/sports/mlb/columnist/gabe-lacques/2023/11/11/shohei-ohtani-free-agent-mlb-contract/71534553007/.
[4] Nathan Goldman & Christina Lewellen, Inside Shohei Ohtani’s Unusual Contract, Pool Thought Leadership (Sep. 23, 2024), https://poole.ncsu.edu/thought-leadership/article/inside-shoehei-ohtanis-unusual-contract/#:~:text=Ohtani’s%20contract%20includes%20an%20extremely,91%20million%20by%20deferring%20payment.
[5] Teddy Ricketson, Shohei Ohtani contract, explained: Breaking down salary, length, and deferrals in Dodgers star’s unique $700M deal, Sporting News (Oct. 5, 2024), https://www.sportingnews.com/us/mlb/los-angeles-dodgers/news/shohei-ohtani-contract-salary-length-deferrals-dodgers/9215d71aaa6d05cd4345ddd4.
[6] Id.
[7] Nathan Goldman & Christina Lewellen, Inside Shohei Ohtani’s Unusual Contract, Pool Thought Leadership (Sep. 23, 2024), https://poole.ncsu.edu/thought-leadership/article/inside-shoehei-ohtanis-unusual-contract/#:~:text=Ohtani’s%20contract%20includes%20an%20extremely,91%20million%20by%20deferring%20payment.
[8] Dan Freedman, A Deep Dive Into Deferred Contract From The 1950s To Today, Forbes (Dec. 14, 2022), https://www.forbes.com/sites/danfreedman/2024/12/12/a-deep-dive-into-deferred-contracts-from-the-1950s-to-today/.
[9] ESPN, 2025 World Series Odds: Dodgers, Yankees, Mets enter spring as favorites, (Feb. 10, 2025), https://www.espn.com/sports-betting/story/_/id/38801876/2025-world-series-odds-mlb-baseball.
[10] Associated Press, Dodgers’ deferred payments top $1 billion to 7 players, ESPN (Dec. 3, 2024), https://www.espn.com/mlb/story/_/id/42760649/dodgers-deferred-payments-top-1-billion-7-players.
[11] Andrey Yushkov, State Individual Income Tax Rates and Brackets, 2024, Tax Foundation (Feb. 20, 2024), https://taxfoundation.org/data/all/state/state-income-tax-rates-2024/.
[12] Julia Kagan, Tax Deferred: Earnings With Taxes Delayed Until Liquidation, Investopedia (Mar. 13, 2025), https://www.investopedia.com/terms/t/taxdeferred.asp#:~:text=Tax%2Ddeferred%20refers%20to%20income,typically%20done%20in%20the%20future.
[13] How Do MLB Players Get Paid? Exploring Their Salary Structures, Baseball Gain (Aug. 30, 2024), https://baseballgain.com/how-do-mlb-players-get-paid/.
[14] Id.
[15] Id.
[16] Breaking Down the “Jock Tax”, H&R Block, https://www.hrblock.com/tax-center/income/wages/the-jock-tax/?srsltid=AfmBOorR_pURBLzAcGCcXxKPKF5hMeMXWwyOS1kXPo0jB8b7cqMIqW3D.
[17] Id.
[18] Colin Salao, How Michael Jordan’s ‘Jock Tax’ Brought Millions to State Budgets, The Street (Apr. 22, 2023), https://www.thestreet.com/sports/how-michael-jordans-jock-tax-brought-millions-to-state-budgets.
[19] Id.
[20] Breaking Down the “Jock Tax”, H&R Block, https://www.hrblock.com/tax-center/income/wages/the-jock-tax/?srsltid=AfmBOorR_pURBLzAcGCcXxKPKF5hMeMXWwyOS1kXPo0jB8b7cqMIqW3D.
[21] MLB Baseball, Los Angeles Dodgers, 2024 Schedule (https://www.mlb.com/dodgers/schedule/2024-04).
[22] Dan Freedman, A Deep Dive Into Deferred Contract From The 1950s To Today, Forbes (Dec. 14, 2022), https://www.forbes.com/sites/danfreedman/2024/12/12/a-deep-dive-into-deferred-contracts-from-the-1950s-to-today/.
[23] Id.
[24] Id.
[25] Id.
[26] Id.
[27] Michael Mayer, MLB Matters: Understanding Deferred Money Contracts, Metsmerized Online, Jul. 1, 2020, https://metsmerizedonline.com/understanding-deferred-money-contracts/.
[28] Id.
[29] Dan Freedman, A Deep Dive Into Deferred Contract From The 1950s To Today, Forbes, Dec. 14, 2022, https://www.forbes.com/sites/danfreedman/2024/12/12/a-deep-dive-into-deferred-contracts-from-the-1950s-to-today/.
[30] Id.
[31] Teddy Ricketson, Shohei Ohtani contract, explained: Breaking down salary, length, and deferrals in Dodgers star’s unique $700M deal, Sporting News, Oct. 5, 2024, https://www.sportingnews.com/us/mlb/los-angeles-dodgers/news/shohei-ohtani-contract-salary-length-deferrals-dodgers/9215d71aaa6d05cd4345ddd4.
[32] Mihael Mccan, et. al., Ohtani’s $680M Deferment Hits Interest Income To Save on Taxes, Sportico, Dec. 12, 2023, https://www.sportico.com/law/analysis/2023/ohtani-interest-free-deferred-money-tax-1234756781/.
[33] Andrey Yushkov, State Individual Income Tax Rates and Brackets, 2024, Tax Foundation, Feb. 20, 2024, https://taxfoundation.org/data/all/state/state-income-tax-rates-2024/.
[34] California strikes out on Ohtani’s blockbuster Dodger deal Tax analysis of Shohei Ohtani’s Salary Deferral, California Center for Jobs & the Economy, https://centerforjobs.org/wp-content/uploads/Ohtani-Tax-Analysis-FINAL.pdf.
[35] Id.
[36] Mihael Mccan, et. al., Ohtani’s $680M Deferment Hits Interest Income To Save on Taxes, Sportico (Dec. 12, 2023), https://www.sportico.com/law/analysis/2023/ohtani-interest-free-deferred-money-tax-1234756781/.
[37] George Skelton, Column: California’s budget relies on the richest taxpayers, and we’re paying the price, Los Angeles Times (Apr. 22, 2024), https://www.latimes.com/california/story/2024-04-22/column-californias-budget-relies-on-the-richest-taxpayers-and-were-paying-the-price.
[38] California strikes out on Ohtani’s blockbuster Dodger deal Tax analysis of Shohei Ohtani’s Salary Deferral, California Center for Jobs & the Economy, https://centerforjobs.org/wp-content/uploads/Ohtani-Tax-Analysis-FINAL.pdf.
[39] Id.
[40] Id.
[41] Major League Baseball Collective Bargaining Agreement, MLB Players Ass’n, 2022, https://www.mlbplayers.com/_files/ugd/4d23dc_d6dfc2344d2042de973e37de62484da5.pdf.
[42] State Taxation of Pension Income Act, 4 U.S.C. § 114(a) (amended 2006).
[43] Id. at § 114(d) (2006).
[44] Debra Tortorelli, Controller Cohen: Statement Regarding Ohtani Contract, California State Controller’s Officer PR24:01 (Jan. 8, 2024), https://www.sco.ca.gov/eo_pressrel_25445.html.
[45] Id.
[46] California Legislature – 2023-2024 Regular Session, SJR-14 Deferred compensation (Mar. 4, 2024), https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=202320240SJR14.
[47] Id.
[48] Paul Jones, California Proposal Would Urge Congress to Block Ohtani-Type Deferred Pay, Tax Notes (Apr. 18, 2024), https://www.taxnotes.com/featured-news/california-proposal-would-urge-congress-block-ohtani-type-deferred-pay/2024/04/17/7jfhp.
[49] Id.
[50] Id.
[51] Id.
[52] Id.
[53] Id.
[54] Id.
[55] Id.
