A new member of the San Diego Chargers wants the team to transfer

$1,000,000 into an escrow account, in his name, for later withdrawal. The player suggests this payment in lieu of the traditional signing bonus. When is this income taxable to him?

Partial list of research material: §451; Rev. Rul. 70-435, 1970-2 C.B. 100; Drysdale, 277 F.2d 413.