Lobby and Ethics Reform: June 2009
Updated Lobbying Disclosure Act Guidance
On June 9, 2009, the Secretary of the Senate and Clerk of the House issued updated guidance on how to interpret the federal Lobbying Disclosure Act (LDA), as updated by the Honest Leadership and Open Government Act of 2007 (HLOGA). This revision incorporates many suggestions Alliance for Justice made in comments submitted in December 2008 on the need to clarify what information must be disclosed on LD-203.
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501(c)3 / 501(c)4 Website Content
IRS provides limited guidance about links between 501(c)(3) and 501(c)(4) websites.
The IRS issued a Technical Advice Memorandum (TAM) that offers some insight into the IRS's view on the extent of separation needed between website content of a 501(c)(3) and its affiliated 501(c)(4). Specifically, the IRS determined that a 501(c)(3) public charity impermissibly intervened in a political campaign by including on its website partisan content from its affiliated 501(c)(4) organization.
This ruling comes less than a year after an internal IRS memorandum issued July 28, 2008 that describes how revenue agents, when examining cases involving alleged campaign intervention by 501(c)(3) organizations, should treat Internet activities.
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