News & Analysis as of

Internal Revenue Service Name and Likeness Student Athletes

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Shook, Hardy & Bacon L.L.P.

NCAA’s $2.8 Billion Athlete Revenue Settlement Receives Final Approval

Not only does Judge Claudia Wilken’s final approval of the In re: College Athlete NIL Litigation settlement provide $2.576 billion in damages for settlement class members, it changes the rules of the game for current and...more

Alston & Bird

NIL Collectives: Don’t Be Blindsided by an IRS Challenge

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If the IRS challenges the tax-exempt status of a name, image, and likeness (NIL) collective, the collective must understand how best to respond. Our Federal Tax Group details what NIL collectives need to know to make the cut....more

Alston & Bird

The IRS’s Latest Play on NIL Collectives: Tax-Exempt Status on the Defensive

Alston & Bird on

Our Federal Tax and Exempt Organizations teams tackle the implications of the IRS chief counsel’s conclusion that nonprofit organizations created to pool donations and develop paid name, image, and likeness (NIL)...more

Fox Rothschild LLP

IRS is coming for NIL collectives

Fox Rothschild LLP on

It is a truism that agencies required to publicly release documents sometimes hold off on releasing those documents until a Friday afternoon, in the hopes it will be overlooked. The IRS lived up to that truism in releasing a...more

Venable LLP

IRS Takes Skeptical View of NIL Collectives

Venable LLP on

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

Vinson & Elkins LLP

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

Vinson & Elkins LLP on

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

Partridge Snow & Hahn LLP

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

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

Baker Donelson

IRS Issues New Guidance on NIL Collectives

Baker Donelson on

On June 9, 2023, the IRS issued memorandum number AM 2023-004, providing guidance on whether organizations that develop paid name, image, and likeness (NIL) opportunities for student-athletes are tax-exempt under section...more

Stinson LLP

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

Stinson LLP on

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

Foster Garvey PC

Sports & Entertainment Spotlight - April 2021 #3

Foster Garvey PC on

“Happy” Tax Day to those of you here in the United States celebrating/commiserating (noting of course that certain taxpayers have until May 17 to file their returns this year). Like taxes, this installment of the Spotlight...more

Fenwick & West LLP

Intellectual Property Bulletin - Fall 2016

Fenwick & West LLP on

Mean Girls v. The Right of Publicity: Lessons Learned From the Lohan and Gravano Lawsuits - On September 1, 2016, a New York appellate court ended two closely watched right of publicity lawsuits brought by Lindsay...more

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