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TOPICS / TAX

NIL organization denied tax-exempt status

The IRS denied tax-exempt status to an organization formed to compensate student-athletes for the use of their name, image, and likeness (NIL), concluding that the organization served private rather than public interests and operated for a substantial nonexempt purpose.

IRS addresses whether college NIL collectives further an exempt purpose

A memo from the IRS Office of Chief Counsel advises that an organization that develops paid NIL opportunities for student-athletes will, in many cases, be operating for a substantial nonexempt purpose—serving the private interests of student-athletes—which is more than incidental to any exempt purpose furthered by the activity.

IRS diagnoses a defect in Mayo Clinic

The Eighth Circuit’s decision
was a partial win for the Service,
which nonetheless does not
acquiesce to the court’s holding
regarding the formal-instruction
requirement for tax-exempt
educational institutions.

Sorting out tax exempts’ UBTI painlessly

To help exempt organizations “silo,” or separately compute, their unrelated business or trade income, three experts who will be giving a presentation on the topic at the upcoming Not-for-Profit Industry Conference offer their thoughts.

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