Advocacy Question of the Week

Question: Can a 501(c)(3) combine committees with a (c)(4)? Can the (c)3 and (c)4 conduct committee meetings together?

Answer: We do not recommend combining committees of related 501(c)(3) and 501(c)(4) organizations. Each organization is a separate legal entity, and must be operated as such. The boards must operate separately and hold distinct meetings.

When the need arises, the members of one board may attend the meetings of the other board as guests, although this is not recommended as a regular practice. By combining committees of the two organizations, it is harder to demonstrate that the two organizations are separate. It is especially important to maintain the separateness of the boards if the 501(c)(4) conducts political activities—you want to reduce the chance that the political activities of the 501(c)(4) will be attributed to the 501(c)(3) or otherwise taint the activities of the 501(c)(3).