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Evolution of NIL—Donor Funded NIL Groups
Nov 08, 2021
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As NCAA institutions, athletes, and other stakeholders continue to adjust to the new normal of name, image, and likeness deals for college athletes, a new trend is emerging: donor and alumni led third party organizations focused on helping athletes g...
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IRS Issues (and Seeks Comments on) Standards for Qualifying an LLC as a 501(c)(3) Entity
Nov 08, 2021
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Traditionally, an entity applying for tax exempt status under Code Section 501(c)(3) will be a corporation. With the rise in popularity of the LLC over the last 25 years, it’s a wonder that LLCs are not used more frequently to apply for federal tax e...
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When Worlds Collide: How Tangible Tax Burdens Attach to Digital Commerce across the Globe (Part 1)
The world is at a crossroads. The early 1990’s saw the internet opening to the general public, followed shortly thereafter by online sales platforms (Book Stacks Unlimited—1992, Amazon.com—1994, and eBay—1995), and social media platforms in the 2000’...
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Today in Tax: Spin-offs, Tax Elections, and Subpart F
Taxpayers Not Allowed to Revoke Tax Elections Based on Later Change in Regulation Regulations frequently change as Congress adopts new policies and the IRS issues new or revised regulations implementing those policy changes. Tax elections based on e...
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Burr Takes Aim . . . This Time at Non-Taxable Scholarships
On September 29, 2021 Senator Richard Burr (R-NC) introduced legislation that would cause student-athletes to pay federal income tax on athletic scholarships if those student-athletes earn more than $20,000 in receipts from monetizing their name, ima...
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NLRB General Counsel Declares That College Athletes Are Employees
On September 29, 2021, General Counsel Jennifer Abruzzo (the “GC”) for the National Labor Relations Board (NLRB) issued General Counsel Memorandum 21-08 (“GC Memo”) announcing that scholarship athletes at private universities playing football in the...
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