For virtually every tax law the cretins in Congress (that is every single member) pass, there is a loophole. There are already holes to walk through if there are any college administrators intelligent enough to read, understand, and adopt. Look at hospitals and major clinics and their ability to adapt and take advantage. The precedent for athletics is set, court tested, and been in use for decades. Can educrats understand, much less implement? I seriously doubt it. FWIW, there are only a handful of schools that can accomplish it, but Texas is tops on that short list.