No but what is different are the players. Adidas funneling money to certain recruits to play for schools sponsored by them in an attempt to procure that person signing with said company down the line. The IRS doesn't care if Nassir Little goes to Miami or UNC, they care about the bottom line and Adidas is a big payday for them.
Where in College you have a booster (or potentially a "network" of boosters), maybe worth a few million, giving a few k to a select # of recruits a year. Instead of the IRS suing one huge billion dollar company in Adidas and claiming conspiracy, they would have to sue each and every booster claiming some type of tax issue and the costs would likely outweigh the returns. You could try to drag the schools into it but unless you can show some type of connection (high burden), it will just be a "rogue booster" and I cant say I disagree. If I decide to go drop a bag for a 2020 5* kid today with Miami having no knowledge and whether or not that kid goes to Miami, how can Miami be liable?
I also don't agree that paying players would result in bags not being thrown around.... Think of it in a real life scenario, would I take 100k to work in miami and be close to my family for 3-4 years, or would I take the same 100k salary, with a 100k "bonus" and live in bama for 3-4 years?
My only suggestion to fix it would be to tweak the finance laws so if these boosters or "foundations" get caught the punishment is severe and would hopefully deter them from continuing the practice.