Overview

Title

To amend the Internal Revenue Code of 1986 to establish special rules relating to which professional sports leagues qualify to be exempt from taxation.

ELI5 AI

Congress is thinking about changing the tax rules so that really big sports leagues, the ones making lots of money, might have to start paying taxes too, especially if they make more than a billion dollars a year. This is like saying super-rich sports teams have to share more of their money with the country.

Summary AI

H.R. 6774 proposes changes to the Internal Revenue Code of 1986, specifically targeting professional sports leagues. The bill aims to apply new rules so that professional sports organizations with annual gross receipts over $1 billion, and involved in activities like managing league business, officiating, or coordinating schedules, cannot qualify for tax exemption. These changes would affect taxable years starting after December 31, 2022. The bill was introduced by Mr. Thompson of California and Mr. Buchanan and referred to the Committee on Ways and Means.

Published

2023-12-13
Congress: 118
Session: 1
Chamber: HOUSE
Status: Introduced in House
Date: 2023-12-13
Package ID: BILLS-118hr6774ih

Bill Statistics

Size

Sections:
1
Words:
311
Pages:
2
Sentences:
9

Language

Nouns: 90
Verbs: 33
Adjectives: 25
Adverbs: 0
Numbers: 15
Entities: 23

Complexity

Average Token Length:
4.67
Average Sentence Length:
34.56
Token Entropy:
4.71
Readability (ARI):
21.34

AnalysisAI

This proposed bill, introduced in the U.S. Congress, seeks to amend the Internal Revenue Code of 1986 in order to clarify which professional sports leagues can qualify for tax-exempt status. Specifically, it aims to exclude organizations with significant activities related to managing sports competitions and which have annual gross receipts exceeding $1 billion from being treated as tax-exempt under certain provisions of the tax code.

Summary of the Bill

The bill proposes specific changes to Section 501 of the Internal Revenue Code. It introduces a new subsection that focuses on professional sports leagues. These leagues, if involved in substantial activities related to managing professional sports competitions and earning over $1 billion in annual gross receipts, will not be eligible for tax exemption. This amendment is intended to take effect for taxable years starting after December 31, 2022.

Summary of Significant Issues

Several issues arise from this proposed legislation:

  1. High Financial Threshold: The bill establishes a threshold of $1 billion in annual gross receipts for determining tax exemption. This figure is substantial and may allow many large sports organizations to remain eligible for tax exemption, potentially undermining the bill's intent to capture all relevant entities in this category.

  2. Ambiguity in Definitions: The language used to define key terms such as "fostering national or international professional sports competitions" is notably broad. This could lead to varying interpretations about which organizations are included, possibly resulting in legal disputes.

  3. Lack of Clarity: Terms like "professional sports league, organization, or association" are not clearly defined. This creates uncertainty about which entities the bill intends to affect, allowing room for diverse legal interpretations that might complicate implementation.

  4. Potential Inconsistencies in Tax Treatment: By singling out professional sports leagues for specific tax rules, the bill could lead to inconsistencies with how other types of businesses are treated under the tax code. This raises concerns about fairness and equitable treatment across different organizational types.

  5. No Enforcement Mechanism: The bill does not outline how compliance will be monitored or enforced, which could lead to difficulties in ensuring adherence. This absence could result in potential tax avoidance by entities meant to fall under the new rules.

  6. Increased Complexity of the Tax Code: Introducing a new subsection specifically for professional sports leagues adds further complexity to the tax code, possibly making compliance more challenging for affected organizations and requiring additional administrative resources for enforcement.

Public Impact

For the general public, this bill may appear as a move to ensure that highly profitable professional sports leagues contribute their fair share of taxes, thereby potentially increasing federal revenue which can be redirected towards public services. However, the high financial threshold implies that only the largest leagues would be affected, which might not significantly change the overall tax landscape.

Stakeholder Impact

Positive Impacts: - Federal Revenue: If successful, the bill could lead to increased federal tax collections from some of the largest sports organizations, contributing positively to public finances. - Fair Competition: Smaller or mid-tier sports leagues that might strive for tax-exempt status but fall below the $1 billion mark may benefit from decreased competition from larger leagues enjoying tax advantages.

Negative Impacts: - Large Sports Leagues: These entities could see their financial strategies altered significantly if they lose tax-exempt status, which might result in changes to how they operate or invest in sports-related activities. - Legal and Administrative Costs: The ambiguity and potential for varied interpretations could result in increased legal and administrative costs for stakeholders as they navigate compliance with the new rules.

In summary, while the bill aims to address issues of tax fairness among professional sports leagues, its high threshold and vague definitions pose challenges that might hinder its effectiveness and lead to unintended consequences. Stakeholders involved will need to consider these aspects carefully as they engage with or respond to the legislative process.

Financial Assessment

The legislation in question, H.R. 6774, specifically targets the financial aspects of professional sports leagues by proposing changes to the Internal Revenue Code of 1986. This bill seeks to establish certain financial thresholds and criteria that could impact the tax-exempt status of these organizations.

Financial Threshold

A central element of the bill is the financial threshold it sets for professional sports leagues to maintain their tax-exempt status. Organizations with annual gross receipts exceeding $1,000,000,000 during any of the five preceding taxable years would not qualify for tax exemption. This is a significant financial reference as it establishes a clear monetary line that separates which sports leagues can benefit from tax exemptions under the existing law.

Relation to Identified Issues

  1. Threshold Concerns: The bill sets the threshold for gross receipts at $1 billion, which raises the issue that many large organizations, especially in the lucrative sports industry, may still avoid taxation. This high threshold means that only the very largest entities would be affected, potentially leaving out significant portions of revenue that could have otherwise contributed to federal taxes. This selective regulation might lead to a tax advantage for affluent sports leagues, impacting federal revenue and potentially exacerbating competitive inequalities in the sports arena.

  2. Ambiguity in Definitions: The bill uses broad language for what constitutes activities that "foster national or international professional sports competitions." By emphasizing financial activities such as managing league business affairs and coordinating schedules, the bill leaves room for debate about which organizations meet these financial activity criteria. This ambiguity could result in legal challenges, where organizations argue their eligibility or exemption status, directly impacting how financial rules are applied across different bodies.

  3. Enforcement and Compliance: Despite the explicit financial delineation in the bill, there is no mention of specific enforcement mechanisms or oversight for monitoring compliance with these new rules. The absence of an enforcement strategy could lead to difficulties in ensuring that organizations adhere to the new financial requirements, raising concerns over potential tax avoidance by entities that deliberately manipulate their financial reporting to stay below the $1 billion threshold.

By introducing these financial criteria specifically for professional sports leagues, the bill also complicates the broader tax code, which may demand additional administrative resources for effective enforcement. A substantial portion of the issues raised by this bill revolves around how these financial thresholds and definitions are applied, interpreted, and enforced, impacting both the leagues and the government’s tax income.

Issues

  • The threshold for gross receipts set at $1,000,000,000 may allow many large organizations to escape the regulation, potentially leading to legal and financial implications. This issue is particularly significant because it could lead to tax advantages for already wealthy sports organizations, thereby impacting federal revenue and possibly giving rise to competitive imbalances in the sports industry (Section 1).

  • The language defining 'fostering national or international professional sports competitions' is broad, which could lead to interpretations that encompass organizations not intended to be covered or allow those that should be covered to claim exemption. This ambiguity can result in legal disputes and inconsistent application of the law (Section 1).

  • The term 'professional sports league, organization, or association' is not clearly defined, creating ambiguity about which entities are affected by the amendment. This lack of clarity can lead to varied interpretations and potential legal challenges (Section 1).

  • By introducing special rules for professional sports leagues, the bill might create inconsistencies with how other business entities are treated, leading to disputes and confusion in the application of the tax code. This inconsistency poses a broader legal and ethical question about fairness in taxation (Section 1).

  • There is no specific mention of an enforcement mechanism or how compliance will be monitored for organizations under this amendment, which could lead to difficulties in ensuring adherence to the new rules and potential tax avoidance (Section 1).

  • Introducing a new subsection in the Internal Revenue Code specifically for professional sports leagues complicates the tax code further, possibly making compliance more challenging for affected organizations and requiring additional administrative resources for enforcement (Section 1).

Sections

Sections are presented as they are annotated in the original legislative text. Any missing headers, numbers, or non-consecutive order is due to the original text.

1. Special rules relating to professional sports leagues Read Opens in new tab

Summary AI

The section amends the Internal Revenue Code to specify that professional sports leagues with substantial activities related to managing sports competitions and having gross receipts over $1 billion cannot be treated as tax-exempt organizations starting from the 2023 tax year.

Money References

  • (a) In general.—Section 501 of the Internal Revenue Code of 1986 is amended by adding at the end the following new subsection: “(s) Special rules relating to professional sports leagues.—No organization shall be treated as described in subsection (c)(6) for any taxable year if such organization or entity— “(1) is a professional sports league, organization, or association, a substantial activity of which is to foster national or international professional sports competitions (including by managing league business affairs, officiating or providing referees, coordinating schedules, managing sponsorships or broadcast sales, operating loan programs for competition facilities, or overseeing player conduct), and “(2) has annual gross receipts in excess of $1,000,000,000 during any of the 5 preceding taxable years.”. (b) Effective date.—The amendment made by this section shall apply to taxable years beginning after December 31, 2022. ---