Analyzing the Prospects of the Unrelated Business Income Tax and §501(c)(3) on Division I Athletic Activities

Abstract

The National Collegiate Athletic Association (NCAA) member schools are generally exempt from paying any income tax on profits made from athletics each year because their missions primarily focus on charitable goals such as education and sportsmanship. However, recent activity from several schools has begun to blur the lines between a for -profit company and that which justifies a tax -exemption as an educational institution. Some critics argue for -profit and profit -making athletic departments should be taxed using the Unrelated Business Income Tax (UBIT), which examines if certain business activities are related to the purpose of an exempt organization or more in-line with a for -profit company. With this concept in mind, we look to see if some of the latest business activities and ventures implemented by intercollegiate athletic departments are protected or subject to the UBIT.