Sports and Tax Exemption - Alliance for Justice

Sports and Tax Exemption


Natalie Roetzel Ossenfort, Tim Mooney, Victor Rivera Labiosa


It’s our first-ever #sportsball edition of the pod! Dig into the tax code a bit, and you’ll discover that tax-exemption and sports fit together like a sports reference and a podcast that doesn’t really cover sports. In other words… perfectly. From amateur athletics, to professional sports leagues, to this newish thing called NIL that allows collegiate athletes to get paid for the billions they earn other people, the IRS and tax law has something to say about all of it. And most importantly, after this episode you will too at your next summer cocktail outing… 

Our Attorneys for This Episode:

Natalie Roetzel Ossenfort Tim Mooney Victor Rivera Labiosa

On this episode:

  • What are tax-exempt organizations?  
  • Amateur athletics as 501(c)(3)s  
  • Major pro leagues had 501(c)(6)s and then dropped them 

Case study: NIL Collectives as 501(c)(3)s  

  • NCAA v Alston 
  • NIL collectives were set up as 501(c)(3) organizations, making tax-deductible.  
  • 2023 IRS GLAM letter concluded that an organization that develops paid NIL opportunities for student-athletes will, in many cases, be operating for a substantial nonexempt purpose (ie, serving the private interests of the student-athletes, instead of providing a real charitable purpose).