I know you do this for a living, so this is as much a question as a statement, but the state income tax deduction, as I understand it, is capped at $10k, including real estate taxes lumped together.
So you can only deduct a total of $10k for all state and local taxes.
So it would only lower his federal taxes by $10k, not $77k.
The TCJA capped the SALT limitation for the years 2018-2025. Which means the cap is expiring. It's my fault anyhow, I do corporate taxes, so we always use enacted (or expiring) rates on a going forward basis. So, yes, there would be a cap for 2025, but not after 2025, unless the cap is re-enacted.
Besides, if you want the far batter answer that I was alluding to previously, it's this (and Nico probably already set up an S-corp 2 years ago).
You have all the money paid into an S-corporation. The S-corporation can then take business deductions against the income. Agent commission, legal fees, accounting fees. VEHICLE EXPENSE. Throw in some expenses for drycleaning and office supplies and anything else that makes sense, like a computer. PAY YOURSELF A MODEST SALARY. What does all of that do:
1. Reduction of federal income tax - not to zero, but it's still a reduction. Chances are, he is still in the highest personal tax bracket, but still.
2. Near-total elimination of payroll taxes.
3. Reduces the state tax as well.
I guarantee if that guy let me structure his business, I would get the EFFECTIVE tax rate on 1.8 million down to around 40%.
And that's not even taking into account multi-state tax strategies. Like doing some of the required NIL tasks (signing autographs, filming videos and promos, etc.) in Nevada, which has no income tax. Set up a UCLA alum function in Vegas, have Nico show up to sign things and host an auction, and BOOM, a good chunk of that 1.8 million starts to be earned in Nevada.