The Internal Revenue System has issued a Generic Legal Advice Memorandum (a “GLAM”) saying that “NIL Collectives” formed to help collegiate athletes monetize their “name, image and likeness” assets are probably not eligible for charitable exemption because they will in many cases be operating for a substantial non-exempt purpose, serving the private interests of the student-athletes. ( AM 2023-004, 6/9/23 .) The GLAM has caused a significant uproar in the college athletics world. In 2021, the National Collegiate Athletic Association adopted an ‘interim policy” permitting student-athletes to be compensated for use of their NIL without impacting their amateur eligibility to compete, subject...