IRS Is Looking at Next Steps on College Athlete Collectives

The IRS is “considering all options” when it comes to issues around the tax-exempt status of name, image, and likeness collectives, including issuing additional guidance, an agency official said Thursday.

The agency is carefully weighing how it wants to move forward on the topic, Lynne Camillo, deputy associate chief counsel at the IRS, said at the 2024 D.C. Bar Tax Conference. She noted, however, that NIL guidance isn’t on the IRS’s most recent priority guidance plan.

• NIL collectives are entities independent from colleges that are focused on funding deals for student-athletes. Some collectives have sought 501(c)(3) tax-exempt status, ...