The IRS Weighs in on Nonprofit NIL Collectives
The IRS on June 9, 2023, released generic legal advice memorandum AM 2023-004, which addresses whether developing paid name, image, and likeness (NIL) opportunities for collegiate student-athletes furthers an exempt purpose under Internal Revenue Code Section 501(c)(3). The memorandum concludes that many 501(c)(3) organizations developing these opportunities...