Go ahead and get that federal legislation and then we will talk. Legislators aren't well known for ironing out all the kinks in other laws that impact their new legislation.That's absurd. If there is federal legislation saying that amateur athletes can profit from their likeness then it would be totally viable to pay them all a base plus bonus package for that likeness.
FTR, I've had plenty of dealings with tax attorneys at much bigger firms than Baker and no decent LLM would say it can't be done. They might say it will be tough but only second rate counsel says you can't do it.
Glad you've have experiences with tax attorneys at firms larger than Baker....kudos. Why don't you run this idea of yours by one of them, the Supreme Court has already decided that scholarships don't count as income which kept the amateur status alive for the tax exemptions. Seriously doubt direct payments will ever pass muster with the IRS or the Supreme Court.