Looks like the collectives can no longer operate under a 501(c) (3) status. Donation to these collectives will no longer be tax deductible.
IRS addresses whether college NIL collectives further an exempt purpose
A memo from the IRS Office of Chief Counsel advises 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...
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