This week, Nonprofit VOTE responded to the IRS proposal to limit the political activities of 501(c)(4) social welfare organizations. Comments are due February 27th.

Nonprofit VOTE and its partners welcome IRS action to stop the rising abuse of 501(c)(4) nonprofits to channel large amounts of secret, undisclosed money into political campaigns.

However, in its attempt to create a clear definition of political activities for 501(c)(4)s, the IRS proposal wrongly re-classifies even nonpartisan voter engagement activities like voter registration, get-out-the-vote, voter guides, and candidate forums as partisan campaign intervention. Nonpartisan voter engagement is absolutely a valid and vital way to promote social welfare and 501(c)(4) organizations should not be limited in their nonpartisan efforts.

In a strongly worded and detailed response, our letter tells the IRS:

  • Don’t create two definitions of nonpartisanship – one for 501(c)(4)s and another for 501(c)(3)s. It would not only be extraordinarily confusing, but would chill the nonpartisan civic engagement work of charities and nonprofits of every type.
  • Apply the same definition of partisan or nonpartisan political activity to all 501(c) exempt organizations, including business associations and labor unions established primarily for a civic purpose. Solely targeting 501(c)(4)s is not a solution.

Throughout our nation’s history the nonprofit sector has played a foundational role of encouraging civic engagement and strengthening democracy. Charities and voluntary associations have long promoted active citizenship including promoting voter participation and voter education. We urge the IRS to use this opportunity to protect and affirm nonpartisan civic activity across all nonprofits, not confuse or dilute it. These official comments expand on Nonprofit VOTE’s initial response.


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