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NIL Collectives react to recent IRS memo

Jun 26, 2023, 3:48 PM

NIL Collectives seek professional tax advice after the IRS released a memo stating that collectives are unlikely to qualify for nonprofit status, eliminating a tax write-off for donors.

NIL Collectives react to recent IRS memo

The Internal Revenue Service made headlines on June 9 when SI reported the IRS released a memo stating that most Name, Image, and Likeness (NIL) Collectives are unlikely to qualify for 501(c)(3) tax-exempt status. In simple terms, donors cannot claim money given to a NIL Collective as a charitable donation on their taxes. 

Matt Brown turned his Extra Points newsletter over to Samantha Bowie, a law student at the Sandra Day O’Connor College of Law at Arizona State, to explain why collectives don’t qualify for nonprofit status. Bowie noted four criteria that must be met to reach 501(c)(3) status.

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