[Mick]

I'm not knowledgeable on tax deductibility of the disparate ways that funds are sourced on behalf of athletic departments. 

I  do know that the 131 football schools have over 200 NIL collectives and are selling most of them as tax deductible. What a number of them are doing is blending the focus of the collectives to reduce the impact of the NIL transfer payments. For example, UMich created a new NIL collective which pays the athletes just 30% of total funds collected and uses the balance for charitable work. Penn State does the same.

Others fold a free-standing nonprofit NIL into a larger operating tax-exempt charity (e.g., a DAF, donor advised fund) in order to refer to the NIL payments as "insubstantial" by comparison to the larger charity's work.

[Mick]

I'm not knowledgeable on tax deductibility of the disparate ways that funds are sourced on behalf of athletic departments. 

I  do know that the 131 football schools have over 200 NIL collectives and are selling most of them as tax deductible. What a number of them are doing is blending the focus of the collectives to reduce the impact of the NIL transfer payments. For example, UMich created a new NIL collective which pays the athletes just 30% of total funds collected and uses the balance for charitable work. Penn State does the same.

Others fold a free-standing nonprofit NIL into a larger operating tax-exempt charity (e.g., a DAF, donor advised fund) in order to refer to the NIL payments as "insubstantial" by comparison to the larger charity's work.