II 

116TH CONGRESS 

1ST SESSION S. 1121 

To amend the Internal Revenue Code of 1986 to exclude major professional 

sports leagues from qualifying as tax-exempt organizations. 

IN THE SENATE OF THE UNITED STATES 

APRIL 10, 2019 

Ms. ERNST (for herself and Mr. KING) introduced the following bill; which was 

read twice and referred to the Committee on Finance 

A BILL 

To amend the Internal Revenue Code of 1986 to exclude 

major professional sports leagues from qualifying as taxexempt organizations. 

1 Be it enacted by the Senate and House of Representa2 tives of the United States of America in Congress assembled, 

3 SECTION 1. SHORT TITLE. 

4 This Act may be cited as the ‘‘Properly Reducing 

5 Overexemptions for Sports Act’’ or the ‘‘PRO Sports 

6 Act’’. 

7 SEC. 2. FINDINGS. 

8 Congress makes the following findings: 

9 (1) The National Hockey League (NHL), PGA 

10 Tour, and Ladies Professional Golf Association 


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1 (LPGA) each have league offices that are registered 

2 with the Internal Revenue Service as nonprofit orga3 nizations under section 501(c)(6) of the Internal 

4 Revenue Code of 1986. 

5 (2) League-wide operations of the NHL, PGA 

6 Tour, and LPGA together generate over 

7 $1,000,000,000 in annual revenue, and these busi8 nesses are unmistakably organized for profit and to 

9 promote their brands. 

10 (3) According to the Internal Revenue Service, 

11 section 501(c)(6) of the Internal Revenue Code of 

12 1986 is for groups looking to promote a ‘‘common 

13 business interest and not to engage in a regular 

14 business of a kind ordinarily carried on for profit’’. 

15 (4) According to the Internal Revenue Service, 

16 businesses that conduct operations for profit on a 

17 ‘‘cooperative basis’’ should not qualify for tax-ex18 empt treatment under section 501(c)(6) of the Inter19 nal Revenue Code of 1986. 

20 SEC. 3. ELIMINATION OF SPECIFIC EXEMPTION FOR PRO21 FESSIONAL FOOTBALL LEAGUES. 

22 (a) IN GENERAL.—Paragraph (6) of section 501(c) 

23 of the Internal Revenue Code of 1986 is amended— 


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1 (1) by striking ‘‘, or professional football 

2 leagues (whether or not administering a pension 

3 fund for football players)’’, and 

4 (2) by inserting ‘‘or’’ after ‘‘real-estate 

5 boards,’’. 

6 (b) EFFECTIVE DATE.—The amendments made by 

7 this section shall apply to taxable years beginning after 

8 December 31, 2019. 

9 SEC. 4. SPECIAL RULES RELATING TO PROFESSIONAL 

10 SPORTS LEAGUES. 

11 (a) IN GENERAL.—Section 501 of the Internal Rev12 enue Code of 1986 is amended by adding at the end the 

13 following new subsection: 

14 ‘‘(s) SPECIAL RULES RELATING TO PROFESSIONAL

15 SPORTS LEAGUES.—No organization or entity shall be 

16 treated as described in subsection (c)(6) if such organiza17 tion or entity— 

18 ‘‘(1) is a professional sports league, organiza19 tion, or association, a substantial activity of which is 

20 to foster national or international professional sports 

21 competitions (including by managing league business 

22 affairs, officiating or providing referees, coordinating 

23 schedules, managing sponsorships or broadcast sales, 

24 operating loan programs for competition facilities, or 

25 overseeing player conduct), and 


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1 ‘‘(2) has annual gross receipts in excess of 

2 $10,000,000.’’. 

3 (b) EFFECTIVE DATE.—The amendment made by 

4 this section shall apply to taxable years beginning after 

5 December 31, 2019. 

Æ 


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