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ON DEMAND: Exempt Organizations Tax Series: Name, Image and Likeness (NIL) Collectives After IRS GLAM 2023-004
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Credit: 0 Credit Hours
Name, Image and Likeness (NIL) collectives have proliferated since the NCAA adopted interim rules in 2021 permitting student-athletes the ability to benefit from their name, image and likeness, including dozens of nonprofit NIL collectives that have obtained 501(c)(3) tax-exempt status from the IRS since that time. On June 9, 2023, the IRS publicly released a generic legal advice memorandum (“GLAM”) 2023-004, concluding 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. Join us as our expert panel discusses the legal analysis outlined in the GLAM, the status of tax-exempt NIL collectives following the publication of the GLAM, and what it means for groups considering the establishment or restructuring of legal entities that provide paid NIL opportunities to college student-athletes.
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Sponsored by: Exempt Organization Committee of the D.C. Bar Taxation CommunityCommunities of Interest: D.C. Bar Arts, Entertainment, Media and Sports Law Community; D.C. Bar Law Student Community
Speakers:
- Meghan Biss, Member, Caplin & Drysdale, Chartered
- Chelsea Rubin, Associate, Morgan, Lewis & Bockius
- Karen Wu, Partner, Perlman & Perlman, LLP (Moderator)
| Your Price | Standard |
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| Non-Member | $40.00 | | D.C. Bar Member | $30.00 | | D.C. Bar Premium Community Member | $0.00 | | D.C. Bar Regular Community Member | $15.00 | | Law Student Community | $15.00 |
| Government and Nonprofit Attorneys | Standard |
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| Non-Member | $15.00 |
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