https://www.foiaball.com/p/ucla-nil-collective-bruins-for-life-charity-donations-shelter-37
How UCLA used a friendly charity to get tax-free NIL money
[url=https://www.foiaball.com/p/ucla-nil-collective-bruins-for-life-charity-donations-shelter-37][/url]
David Covucci
Emails show UCLA steered donors to a 501c3 to claim tax deductions while earmarking the funds for football.
On April 10, 2025, reports revealed that Tennessee quarterback Nico Iamaleava wanted a bigger NIL deal with the Volunteers.
The timing, a few days before the transfer portal opened, wasn't coincidental. It sent a clear message: Someone out there would pay him a lot more.
That same night, donors at the school that landed him pledged $60,000.
But UCLA didn't have those boosters send checks to its NIL collective, Bruins for Life.
Instead, its athletics department steered the money to a local charity for at-risk youth.
Which is run by the co-founder of Bruins for Life.
When the Supreme Court upended college athletics in 2021 and kicked off the Name, Image, and Likeness era, it created a torrent of loose cash.
NIL collectives quickly formed to funnel that money to programs. Ostensibly, they worked as facilitators to help student-athletes find advertising deals and earn compensation.
But the system had little oversight, with eager boosters and creative accountants willing to game the system.
Some of these NIL firms applied for tax-exempt status, known as a 501c3.
In this new world, if you were a local pontoon boat dealer or hot tub magnate, instead of under-the-table wads of cash, you could essentially give directly to your team's best players.
And write it all off on your taxes.
The IRS quickly determined these NIL collectives were not there to help the community. In a series of rulings beginning in 2023, the agency determined collectives didn't merit 501c3 status.
Its logic was fairly straightforward. Because NIL collectives "distribute[d] the majority of funds received to student-athletes, and not for a charitable purpose," they weren't charities.
While collectives could still apply for a ruling, the IRS made it clear the barrier for approval was high.
Newer ones skipped that step entirely.
When Texas Aggies United ?utm_campaign=how-ucla-used-a-friendly-charity-to-get-tax-free-nil-money&utm_medium=referral&utm_source=www.foiaball.com]launched after the ruling, it didn't bother trying, noting at its onset that contributions to it were not tax-deductible.
Bruins for Life, UCLA's official football collective, debuted on Dec. 3, 2024.
It was co-founded by James Washington, a former safety for UCLA with an impressive on-field pedigree.
In 1985, he was named MVP of the Fiesta Bowl after the Bruins beat the Miami Hurricanes 39-37. In the NFL, he won two Super Bowls with the Dallas Cowboys.
According to his LinkedIn, he worked for UCLA for six years as a director of development, spearheading major gifts
His partner in the endeavor, John Manuck, is an engineering entrepreneur who started a high-tech polymer firm.
In 2013, his company hosted a visit from Barack Obama and Joe Biden, who announced a $350 million investment in a 3-D printing partnership that included Manuck's firm and the Tennessee laboratory that refined uranium for the first nuclear bomb.
College football really does have it all.
Bruins for Life's stated mission is to "create pathways for UCLA athletes to explore NIL opportunities," helping them "monetize their brand."
On its website, the collective explicitly states it is not a 501c3 and that donations to it are not tax-deductible.
Or, stated. Its website was taken down this week.
But before then, when visitors clicked to donate, it didn't tell them to mail money to the NIL collective.
Instead, it listed Shelter 37, Inc., a tax-exempt charity that helps provide opportunities and mentoring for youth in the Los Angeles area.
Shelter 37's president is James Washington.
The former chairman of its board?
John Manuck.
The IRS grants charities tax-exempt status on the grounds that private money going directly to help others is a public good.
It's an essential tool to help funds flow to people who need them. Especially because donors are happy to oblige when that giving can lower their tax bill.
But as the IRS noted in its NIL collective ruling, charities are expected to further the public well-being.
And anyone who watched the first few UCLA games this year would … never mind.
Shelter 37, though, is a 501c3 charity that is "eligible to receive tax-deductible charitable contributions."
Its 2023 Form 990 details the organization's mission: "Provide educational training and programs to underserved and disengaged young adults in order to equip them with skills and knowledge."
It does so through a hodgepodge of activities that include mentorship, tuition support, public appearances by Washington, and a home ownership program.
The website doesn't give the appearance of an extremely active organization, littered with stock photos.
Its events page has just two entries in the past two years, both Thanksgiving turkey drives. Its blog has one post since November 2021.
Under sponsorship opportunities, it makes a small mention of UCLA, saying that fundraising events like its golf tournaments can cover the cost of additional programs, which include a youth football camp hosted by UCLA.
But an active relationship exists behind the scenes.
Emails from UCLA's fundraising department, obtained by FOIAball, show the school is steering money to the charity, with explicit notes that it be earmarked for football NIL.
In one email, a booster forwarded the approval message for a $15,000 grant from a donor-advised fund to Shelter 37.
"This is the grant payable to UCLA Football," they wrote.
FOIAball spoke with several prominent attorneys and professors well-versed in tax law.
We initially presented the situation as hypothetical.
Bloomberg tax columnist Andrew Leahey told FOIAball, "If that is indeed what is happening, it is, potentially, a huge issue."
When sent the documents to review, he replied with a grimace emoji.
"Pretty blatant, pretty bad," Leahey added. "Woof."
After viewing the emails, Lloyd Hitoshi Mayer, a Notre Dame professor who focuses on non-profit tax law, said what was happening was clear.
"UCLA athletics is encouraging their donors to engage in fraud."
-------------------------------------
You can read the rest in the link foiaball link above...just wanted to give the gist.
How UCLA used a friendly charity to get tax-free NIL money
[url=https://www.foiaball.com/p/ucla-nil-collective-bruins-for-life-charity-donations-shelter-37][/url]
David Covucci
Emails show UCLA steered donors to a 501c3 to claim tax deductions while earmarking the funds for football.
On April 10, 2025, reports revealed that Tennessee quarterback Nico Iamaleava wanted a bigger NIL deal with the Volunteers.
The timing, a few days before the transfer portal opened, wasn't coincidental. It sent a clear message: Someone out there would pay him a lot more.
That same night, donors at the school that landed him pledged $60,000.
But UCLA didn't have those boosters send checks to its NIL collective, Bruins for Life.
Instead, its athletics department steered the money to a local charity for at-risk youth.
Which is run by the co-founder of Bruins for Life.
When the Supreme Court upended college athletics in 2021 and kicked off the Name, Image, and Likeness era, it created a torrent of loose cash.
NIL collectives quickly formed to funnel that money to programs. Ostensibly, they worked as facilitators to help student-athletes find advertising deals and earn compensation.
But the system had little oversight, with eager boosters and creative accountants willing to game the system.
Some of these NIL firms applied for tax-exempt status, known as a 501c3.
In this new world, if you were a local pontoon boat dealer or hot tub magnate, instead of under-the-table wads of cash, you could essentially give directly to your team's best players.
And write it all off on your taxes.
The IRS quickly determined these NIL collectives were not there to help the community. In a series of rulings beginning in 2023, the agency determined collectives didn't merit 501c3 status.
Its logic was fairly straightforward. Because NIL collectives "distribute[d] the majority of funds received to student-athletes, and not for a charitable purpose," they weren't charities.
While collectives could still apply for a ruling, the IRS made it clear the barrier for approval was high.
Newer ones skipped that step entirely.
When Texas Aggies United ?utm_campaign=how-ucla-used-a-friendly-charity-to-get-tax-free-nil-money&utm_medium=referral&utm_source=www.foiaball.com]launched after the ruling, it didn't bother trying, noting at its onset that contributions to it were not tax-deductible.
Bruins for Life, UCLA's official football collective, debuted on Dec. 3, 2024.
It was co-founded by James Washington, a former safety for UCLA with an impressive on-field pedigree.
In 1985, he was named MVP of the Fiesta Bowl after the Bruins beat the Miami Hurricanes 39-37. In the NFL, he won two Super Bowls with the Dallas Cowboys.
According to his LinkedIn, he worked for UCLA for six years as a director of development, spearheading major gifts
His partner in the endeavor, John Manuck, is an engineering entrepreneur who started a high-tech polymer firm.
In 2013, his company hosted a visit from Barack Obama and Joe Biden, who announced a $350 million investment in a 3-D printing partnership that included Manuck's firm and the Tennessee laboratory that refined uranium for the first nuclear bomb.
College football really does have it all.
Bruins for Life's stated mission is to "create pathways for UCLA athletes to explore NIL opportunities," helping them "monetize their brand."
On its website, the collective explicitly states it is not a 501c3 and that donations to it are not tax-deductible.
Or, stated. Its website was taken down this week.
But before then, when visitors clicked to donate, it didn't tell them to mail money to the NIL collective.
Instead, it listed Shelter 37, Inc., a tax-exempt charity that helps provide opportunities and mentoring for youth in the Los Angeles area.
Shelter 37's president is James Washington.
The former chairman of its board?
John Manuck.
The IRS grants charities tax-exempt status on the grounds that private money going directly to help others is a public good.
It's an essential tool to help funds flow to people who need them. Especially because donors are happy to oblige when that giving can lower their tax bill.
But as the IRS noted in its NIL collective ruling, charities are expected to further the public well-being.
And anyone who watched the first few UCLA games this year would … never mind.
Shelter 37, though, is a 501c3 charity that is "eligible to receive tax-deductible charitable contributions."
Its 2023 Form 990 details the organization's mission: "Provide educational training and programs to underserved and disengaged young adults in order to equip them with skills and knowledge."
It does so through a hodgepodge of activities that include mentorship, tuition support, public appearances by Washington, and a home ownership program.
The website doesn't give the appearance of an extremely active organization, littered with stock photos.
Its events page has just two entries in the past two years, both Thanksgiving turkey drives. Its blog has one post since November 2021.
Under sponsorship opportunities, it makes a small mention of UCLA, saying that fundraising events like its golf tournaments can cover the cost of additional programs, which include a youth football camp hosted by UCLA.
But an active relationship exists behind the scenes.
Emails from UCLA's fundraising department, obtained by FOIAball, show the school is steering money to the charity, with explicit notes that it be earmarked for football NIL.
In one email, a booster forwarded the approval message for a $15,000 grant from a donor-advised fund to Shelter 37.
"This is the grant payable to UCLA Football," they wrote.
FOIAball spoke with several prominent attorneys and professors well-versed in tax law.
We initially presented the situation as hypothetical.
Bloomberg tax columnist Andrew Leahey told FOIAball, "If that is indeed what is happening, it is, potentially, a huge issue."
When sent the documents to review, he replied with a grimace emoji.
"Pretty blatant, pretty bad," Leahey added. "Woof."
After viewing the emails, Lloyd Hitoshi Mayer, a Notre Dame professor who focuses on non-profit tax law, said what was happening was clear.
"UCLA athletics is encouraging their donors to engage in fraud."
-------------------------------------
You can read the rest in the link foiaball link above...just wanted to give the gist.