Event

Earlier this summer, the IRS published a memorandum, casting serious doubt on whether NIL collectives qualify for tax-exempt status under Section 501(c (3) of the Internal Revenue Code. Beyond the NIL context, and while not directly addressed in the IRS memorandum, the memorandum raises questions regarding whether (and to what extent) an organization described in Section 501(c)(3) of the Code can rely on a favorable determination letter from the IRS. This presentation will explore (1) the consequences the memorandum may have on NIL collectives relying on a favorable IRS determination letter; (2) the rules pertaining to a tax-exempt organization’s reliance on its favorable determination letter; and (3) when retroactive revocation may be appropriate for organizations that filed a Form 1023 with a material omission or misstatement of fact.

Key topics to be discussed:

• The tax-exempt status of NIL collectives after recent IRS guidance
• Tax-exempt organization reliance on favorable IRS determination letters
• Retroactive vs. prospective revocation of tax-exempt status
• Strategies for guarding tax-exempt status

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MichaelBest&Friedrich2023