In recent years, many name, image and likeness (NIL) collectives have sought tax-exempt status from the IRS. These collectives are formed for the benefit of college student-athletes and solicit and provide financial support from business “boosters.” Some of the entities may qualify as tax exempt if their mission and activities can be shown to primarily benefit public interests. But the IRS has made clear that most NIL collectives provide private benefits at odds with tax-exempt status. Recent IRS private letter rulings have denied NIL collective applicants, stating that student-athletes aren’t appropriate charitable interests. Contact us for more information about this issue.
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