[EL] a query

John Pomeranz jpomeranz at harmoncurran.com
Wed Sep 17 21:55:36 PDT 2014


You mean a 501(c)(4) and a 527, right?  There are significant differences between those types of organizations.

All 527s are required to disclose their donors, if not to the FEC as a political committee, or to a state election authority as a "Qualified State or Local Political Organization," then to the IRS on Form 8871.  501(c)(4)s need not disclose any donors publicly.  (They do need to report major donors to the IRS on a non-public document,)
	
Furthermore, 501(c)(4)s must be primarily engaged in "social welfare" activity to maintain their 501(c)(4) status, and social welfare activity does not include political campaign intervention (under the IRS definition of political activity, which is MUCH broader than the limited scope of activities that may be constitutionally regulated under campaign finance law).

So, in short, 527s are much more subject to donor disclosure, but 501(c)(4)s may spend far less of their resources engage in political activity.


John Pomeranz
Harmon, Curran, Spielberg & Eisenberg, LLP
1726 M Street, NW, Suite 600
Washington, DC  20036
p: 202.328.3500
f: 202.328.6918
e: jpomeranz at harmoncurran.com 



-----Original Message-----
From: law-election-bounces at department-lists.uci.edu [mailto:law-election-bounces at department-lists.uci.edu] On Behalf Of Frank Askin
Sent: Thursday, September 18, 2014 12:26 AM
To: Rick Hasen
Cc: law-election at UCI.edu
Subject: [EL] a query

(s there any real difference in operations between a c(4) and a 537 whose major purpose is NOT funding federal elections?  As I uderstand it, Neither has to file with the FEC and both have to file with the IRS and list major donors. In ether case are the donors publicly available? FRANK


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