Are NIL Collectives Breaking IRS Rules? What You Need to Know
In 2023, the IRS Chief Counsel released Memorandum AM 2023-004, which examined whether Name, Image, and Likeness (NIL) collectives, established to support college athletes, qualify for tax-exempt status under Section 501(c)(3). The memorandum concluded that many of these collectives fail to meet the necessary criteria because they primarily serve private interests—specifically benefiting student-athletes directly.
