IRS Memo May Deter Athlete NIL Organizations from Going Nonprofit

A June 2023 IRS memo that has disputed the appropriateness of tax-exempt status for Name, Image, and Likeness collectives—organizations that develop paid opportunities for college athletes—will likely mean more NIL collectives try a for-profit structure, rather than attempt to meet the requirements for an exemption. That's according to Christopher A. Jones, who spoke to Law360 about the memo.

Mr. Jones is a member of Ballard Spahr's Tax Group and a co-author of a Ballard Spahr alert on this topic,  "IRS Addresses Non-Exempt Tax Status for NIL Organizations."

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