Name and Likeness, 501(c)(3)

Emerging Employee and Student Handbook Updates for the 2024-2025 School Year

Venable LLP on 3/4/2024

Each year, new issues, technologies, and events impact the way that independent schools set and carry out their expectations, values, and procedures in their communities. As independent schools embark on the 2024-2025 school...more

IRS Addresses Non-Exempt Tax Status for NIL Organizations

Ballard Spahr LLP on 6/28/2023

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

IRS Takes Skeptical View of NIL Collectives

Venable LLP on 6/27/2023

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

IRS Internal Memorandum Questions NIL Collectives’ 501(c)(3) Tax-Exempt Status

Vinson & Elkins LLP on 6/23/2023

The IRS recently issued an internal memorandum to the effect that many Name-Image-Likeness (NIL) collectives will not qualify for 501(c)(3) tax-exempt status, including those that had previously obtained tax exemption letters...more

Donations Made to Nonprofit Name Image Likeness Collectives are Not Tax Exempt

Partridge Snow & Hahn LLP on 6/21/2023

In 2021, the National Collegiate Athletic Association (“NCAA”) adopted a policy that permitted student athletes to be compensated for the use of their name, image, and likeness (“NIL”). Since then, organizations have been...more

Pass Interference: Potential Tax Implications of NIL Collectives in College Sports

Stinson LLP on 9/26/2022

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