Items like apparel and souvenir sales are already considered UBI. You can consider all revenue directly related to sports as UBI for all I care.

And yes, I'm totally fine with endowing coaches salaries. This indirectly benefits students as well. If a coach's salary is not paid through endowed funds, it is paid through operating funds...which for most schools is tuition. I'd rather have as much tuition dollars as possible going towards programming.

Also, we're again focusing on the top 1% without considering the impact on the 99%. While ND having an endowed coaches position a luxury, at another school, it could be the difference between cutting or keeping a sport.

Consider also that if a football coaches salary is fully or partially paid for through endowed funds, that expense would not be allowed to reduce your UBIT base. Therefore, by doing it through UBIT, you are indirectly taxing the donation. However, by taxing the donation directly, you are punishing all the schools that lose money on sports just to get at the 1%.

If your argument is that schools shouldn't have any donor funded extracurricular activities, its a whole other discussion.