The NCAA’s adoption of an Interim Name, Image and Likeness (NIL) Policy opened the door for donors, alumni and fans to effectively pay college athletes, either directly or through NIL “collectives.” With a growing number of donor groups forming NIL collectives as not-for-profit entities, there are questions about whether or not these collectives truly qualify as charitable organizations for tax purposes.

On June 21, 2021, the U.S. Supreme Court turned college athletics on its head by ruling that players have the right to accept money for his or her name, image, and likeness (NIL), and effective July 1, 2021, the NCAA adopted an Interim Name, Image, and Likeness Policy. Therefore, amateur athletes can be paid to promote products, services and businesses.