A few years ago, there was a push to create nonprofit, tax-exempt NIL collectives, putatively tax-exempt organizations that collected donations and then used those donations to pay college athletes.
The IRS eventually looked at NIL collectives and determined that private benefit was central to NIL collectives and that thus they didn’t qualify as tax-exempt. The IRS’s determination ruined the market for NIL collectives, though that soon proved unimportant, as the NCAA ultimately agreed to …
