[EL] Question about c(4) finances

[Ellen Aprill]

If you google "501(c)(4) daisy chains," a lot of material comes up, from
various publications and groups.



The 2013 Proposed Regulations (78 FR 71535 (2013)), which, of course, have
been withdrawn, but which the IRS says will be revised and re-proposed in
2016 (but not applicable to the 2016 election) included this issue. The
last proposed rule, called "Attribution" was designed to address these
daisy chains. The recent IRS summary of all the comments on the Proposed
Regulations (which were released in connection with testimony of the CIR to
a Congressional committee) discusses the mixed response to these proposed
attribution rules for grants to other 501(c)'s.


I tried to attach both of these documents in an earlier email, but it got
bounced for being too large a file.  If anyone wants these documents, email
me off-line and I will send them.



  Ellen



-------
Ellen P. Aprill
John E. Anderson Professor of Tax Law
Loyola Law School
919 Albany Street
Los Angeles, CA 90015
213-736-1157

On Tue, Nov 24, 2015 at 9:17 AM, Wesley Joe <wjoe at wtfonline.org> wrote:

> I seem to recall having seen somewhere that C4s sometimes spend 48% of
> their money on elections and then give the rest to another C4 that then
> spends 48% and so on.  Does anyone know of an example of this?  Thanks
> in advance for any help.
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