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The Tax Exempt & Government Entities Division (TE/GE) of the Internal Revenue Service (IRS) recently published a program letter outlining the Division’s priorities in fiscal year 2025. The Division lists “tax-exempt...more
The following is a review of notable cases and regulatory developments for nonprofit organizations at the federal and state levels during the last two years....more
In recent guidance, the IRS blew the whistle on claims of tax-exempt status by organizations formed to provide opportunities for student athletes to monetize their “name, image and likeness” (“NIL”)....more
Summary - The IRS recently advised that many organizations that develop paid name, image, and likeness—known as NIL—opportunities for college student-athletes are not eligible for tax-exempt status under Internal Revenue...more
In a recent memorandum issued by the Office of Chief Counsel, the Internal Revenue Service (IRS) concluded that many "NIL Collectives" may not qualify as tax-exempt under Section 501(c)(3) of the Internal Revenue Code of...more
Is it charitable to donate to a group that facilitates opportunities for athletes at a particular college? The IRS thinks not. In a recent memo released from the office of the IRS Chief Counsel, the IRS asserts that this...more
On June 9, 2023, the IRS issued memorandum number AM 2023-004, providing guidance on whether organizations that develop paid name, image, and likeness (NIL) opportunities for student-athletes are tax-exempt under section...more
Conference realignments. TV deals continuing to soar. Name, image and likeness. If there is one thing that has recently come to define college sports, it is the constant flux and the ebb and flow of change permeating the...more