96-809 A
CRS Report for Congress
Received through the CRS Web
Lobbying Regulations on Non-Profit Organizations
Updated May 19, 1998
Jack H. Maskell
Legislative Attorney
American Law Division
Congressional Research Service ˜ The Library of Congress
Lobbying Regulations on Non-Profit Organizations
Summary
Charitable, religious or educational organizations which are exempt from federal
income taxation under Section 501(c)(3) of the Internal Revenue Code (26 U.S.C. §
501(c)(3)), which have the privilege of receiving contributions from private parties
that are tax-deductible for the contributor, may not engage in lobbying activities
which constitute a “substantial part” of their activities if they wish to preserve this
preferred tax-exempt status. “Civic leagues or organizations not operated for profit
but operated exclusively for the promotion of social welfare ....,” tax exempt under
Section 501(c)(4) of the Internal Revenue Code, on the other hand, have no tax
consequence for lobbying or advocacy activities. (If a 501(c)(4) organization receives
federal funds in the form of a “grant” or loan, however, then there are further
restrictions on its “lobbying activities,” discussed below.) Labor and agricultural
organizations, tax-exempt under Section 501(c)(5) of the Internal Revenue Code, and
business trade associations and chambers of commerce, exempt from federal income
taxation under Section 501(c)(6), also have no specific limitations upon their
lobbying activities as a result of their tax-exempt status.
A provision of law enacted in 1995 as Section 18 of the Lobbying Disclosure
Act, commonly called the “Simpson Amendment,” prohibits section 501(c)(4) civic
leagues and social welfare organizations from engaging in any “lobbying activities,”
even with their own private funds, if the organization receives any federal grant, loan,
or award. Because of the definitions under the Lobbying Disclosure Act, however,
the “Simpson Amendment” limitations do not appear to apply to “grass roots”
lobbying or public advocacy, nor to lobbying State or local officials. Similarly
exempt are: testifying before a congressional committee, subcommittee, or task force;
submitting written testimony for inclusion in the public record; or responding to
notices such as in the Federal Register which solicit communications from the public.
Federal contract or grant money may not be used for any lobbying, unless
authorized by Congress. Under current federal provisions, no organization,
regardless of tax status, may be reimbursed out of federal contract or grant money for
any lobbying activities, or for other advocacy or political activities, unless authorized
by Congress. This applies to direct or “grass roots” lobbying campaigns at the State,
local or federal level (but exempts providing technical and/or factual information
related to the performance of a grant or contract when in response to a documented
request). The provision of law commonly referred to as the “Byrd Amendment” also
expressly prohibits federal grantees, contractors, recipients of federal loans or
cooperative agreements from using federal monies to “lobby” with respect to the
awarding or modification of such contracts, grants, loans, or agreements.
Finally, organizations, other than churches or their affiliates, which meet the
threshold expenditure requirements must register employees who are paid to lobby
Congress or certain executive branch officials, when those employees make direct
lobbying contacts and engage in lobbying over a certain percentage of their time.
Registration and reporting are required under the Lobbying Disclosure Act of 1995.
Contents
Section 501(c)(3) Charitable Organizations . . . . . . . . . . . . . . . . . . . . . . . . 1
Section 501(c)(4) Civic Organizations . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
Section 501(c)(5) Labor Organizations and
501(c)(6) Trade Associations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
Non-profit Organizations Which Receive Federal Funds . . . . . . . . . . . . . . . 3
501(c)(4) Organizations Receiving Grants . . . . . . . . . . . . . . . . . . . . . 3
Restrictions on Use of Federal Funds Generally . . . . . . . . . . . . . . . . . 5
Lobbying Disclosure Requirements for Non-Profit Organizations . . . . . . . . 6
Additional Reading . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
Lobbying Regulations on
Non-Profit Organizations
This report is intended to provide a brief overview of the various potential
restrictions, rules or regulations upon lobbying activities of non-profit organizations.
There are several overlapping laws, rules and regulations which may apply to
non-profit organizations that engage in lobbying activities. In some instances, the
rules and restrictions that apply may be determined by the section of the Internal
Revenue Code under which the organization holds its tax-exempt status. In other
instances, certain rules and regulations may apply depending on whether the
organization receives federal grants, or federal contracts. It should be noted that the
definitions of the terms “lobbying” or “advocacy” activities, and what those activities
may encompass under the several regulations or statutes, may vary among the
different regulations and rules.
Section 501(c)(3) Charitable Organizations
Organizations which are exempt from federal income taxation under Section
501(c)(3) of the Internal Revenue Code (26 U.S.C. § 501(c)(3)) are community
chests, funds, corporations or foundations “organized and operated exclusively for
religious, charitable, scientific, testing for public safety, literary, or educational
purposes.” These charitable organizations, which have the privilege of receiving
contributions from private parties which are tax-deductible for the contributor under
26 U.S.C. § 170(a)), are limited in the amount of lobbying in which they may engage
if they wish to preserve this preferred tax-exempt status from the federal
government.1
A charitable organization exempt from federal taxation under § 501(c)(3) may
not engage in lobbying activities which constitute a “substantial part” of its activities.
In 1976, a “safe harbor” was given to 501(c)(3) organizations where they could elect
to come within specific percentage limitations on expenditures to assure that no
violations of the “substantial part” test would incur, or could remain under the old,
unspecified “substantial part” test.2 The limitations upon organizational expenditures
for covered lobbying activities are 20% of the first $500,000 of total exempt purpose
expenditures of the organization, then 15% of the next $500,000 in exempt purposes
expenditures, then 10% of the next $500,000 in expenditures, and 5% of the
organization’s expenditures over $1,500,000. In no event may a covered charitable
1 26 U.S.C. §§ 501(c)(3), 501(h), 4911, 6033; see IRS Regulations at 55 F.R. 35579-
35620 (August 31, 1990), 26 C.F.R. Parts 1, 7, 20, 25, 53, 56, and 602.
2 Religious organizations are not permitted to make the election to come within the
specific monetary lobbying guidelines under 26 U.S.C. § 501(h), 26 U.S.C. § 501(h)(5).
CRS-2
organization spend more than $1,000,000 on lobbying activities. There is a separate
“grass roots” expenditure limit of 25% of the direct lobbying limits.3
The activities covered under the limitations on lobbying by charitable
organizations generally encompass direct or indirect “grass roots” lobbying, but
exempt nonpartisan analysis, study or research; advice or assistance given at the
request of a governmental body; “self-defense” communications before governmental
bodies; contacts with the organization’s bona fide members; and contacts unrelated
to affecting legislation.
Section 501(c)(4) Civic Organizations
Organizations which are tax exempt under section 501(c)(4) of the Internal
Revenue Code are generally described as “[c]ivic leagues or organizations not
operated for profit but operated exclusively for the promotion of social welfare ....”
If a civic league or social welfare organization is tax exempt under § 501(c)(4) of the
Internal Revenue Code, there is generally no tax consequence for lobbying or
advocacy activities. In fact, in upholding the limitations on lobbying by 501(c)(3)
charitable organizations against First Amendment challenges, the Supreme Court
noted that a 501(c)(3) organization could establish a 501(c)(4) affiliate through which
its First Amendment expression could be exercised through unlimited lobbying and
advocacy.
4 If a 501(c)(4) organization receives federal funds in the form of a “grant”
or loan, however, then there are further restrictions on its “lobbying activities,”
discussed below.
Section 501(c)(5) Labor Organizations and
501(c)(6) Trade Associations
Labor and agricultural organizations are tax-exempt under section 501(c)(5) of
the Internal Revenue Code, and business trade associations and chambers of
commerce are exempt from federal income taxation under section 501(c)(6). Neither
labor or agricultural organizations, nor business trade associations or chambers of
3 See 26 U.S.C. § 4911. The Supreme Court has upheld such loss of special tax-
exempt privilege for “substantial” lobbying, noting that although lobbying is a protected
First Amendment right, and although the government may not indirectly punish an
organization for exercising its constitutional rights by denying benefits to those who
exercise them, lobbying activities are not one of the contemplated “exempt functions” of
these charitable, educational organizations for which they have received the preferred tax
status. Since contributions to the organization by private individuals are eligible for a
deduction from the donor’s federal income tax, the Government is in effect subsidizing
those private contributions to the organization, and the Court found that Congress does not
have to “subsidize” such lobbying activities of private organizations through preferred tax
status of receiving deductible contributions if it does not chose to do so, as long as other
outlets for the organization’s unlimited, protected First Amendment expression exist. Regan
v. Taxation With Representation of Washington, 461 U.S. 540, 544-546 (1983).
4 Regan v. Taxation With Representation of Washington, supra at 544-546 (Opinion
of the Court), see also 552-553 (Blackmun concurring).
CRS-3
commerce, have any specific limitations upon their lobbying activities as a result of
their tax-exempt status.5
Non-profit Organizations Which Receive Federal Funds
501(c)(4) Organizations Receiving Grants. Restrictions on “lobbying
activities” by certain non-profit groups, as a condition to receiving federal grants and
loans, were enacted into law in 1995. Section 18 of the Lobbying Disclosure Act of
1995
6 places statutory restrictions upon the lobbying activities of non-profit civic and
social welfare organizations which are tax-exempt under section 501(c)(4) of the
Internal Revenue Code. This provision, which is commonly called the “Simpson
Amendment,” prohibits section 501(c)(4) civic leagues and social welfare
organizations from engaging in any “lobbying activities,” even with their own private
funds, if the organization receives any federal grant, loan, or award. 2 U.S.C. § 1611.
The restrictions of the Simpson Amendment originally covered all 501(c)(4)
organizations which received federal monies by way of an “award, grant, contract,
loan or any other form.”
7 The term “contract,” however, was subsequently removed
from the provision by P.L. 104-99, Section 129, leaving the prohibition on lobbying
activities with an organization’s own funds as a condition to the receipt of federal
moneys only upon 501(c)(4) grantees and those seeking an award or loan, but
allowing unlimited lobbying activities with organizational funds for 501(c)(4)
contractors of the federal government. The Simpson Amendment now reads:
An organization described in section 501(c)(4) of the Internal
Revenue Code of 1986 which engages in lobbying activities shall not be
eligible for the receipt of Federal funds constituting an award, grant, or
loan.
The legislative history of the provision clearly indicates that a 501(c)(4)
organization may separately incorporate an affiliated 501(c)(4), which would not
receive any federal funds, and which could engage in unlimited lobbying. Th
8
e
method of separately incorporating an affiliate to lobby, which was described by the
amendment’s sponsor as “splitting,” was apparently intended to place a degree of
separation between federal grant money and private lobbying, while permitting an
organization to have a voice through which to exercise its protected First Amendment
5 Note, however, pass-through rules concerning reporting requirements and non-
deductibility as business expenses of dues paid to associations which lobby. Omnibus
Budget Reconciliation Act of 1993, 26 U.S.C § 162(e)(3), 26 U.S.C. § 6033(e)(1). See
discussion in Hopkins, The Law of Tax-Exempt Organizations, 6th Edition, § 29.5 (1995
Cumulative Supplement 125-131) (1992).
6 P.L. 104-65, 109 Stat. 691, 703-704, as amended by P.L. 104-99, Section 129, 110
Stat. 34.
7 P.L. 104-65, Section 18, 109 Stat. 704. Emphasis added.
8 H.R. Rpt. No. 104-339, 104th Congress, 1 Session, at 24 (1995).
st
CRS-4
rights of speech, expression and petition. As stated by Senator Simpson: “If the
9
y
decided to split into two separate 501(c)(4)’s, they could have one organization
which could both receive funds and lobby without limits.”
10
It may also be noted that while § 501(c)(4)’s which receive certain federal funds
may not engage in “lobbying activities,” the term “lobbying activities” as used in the
“Simpson Amendment” prohibition in Section 18 of the Lobbying Disclosure Act is
defined in Section 3 of that legislation to include only direct “lobbying contacts and
efforts in support of such contacts” such as preparation, planning, research and other
background work intended for use in such direct contacts. A “lobbying contact” is
11
an “oral or written communication (including an electronic communication) to a
covered executive branch official or a covered legislative branch official” which
concerns the formulation, modification or adoption of legislation, rules, regulations,
policies or programs of the federal government. Organizations which use their own
12
private resources to engage only in “grass roots” lobbying and public advocacy
(including specifically any communication that is “made in a speech, article,
publication or other material that is distributed and made available to the public, or
through radio, television, cable television, or other medium of mass
communication”) would, therefore, not appear to be engaging in any prohibite
13
d
“lobbying activities” under this provision. The Lobbying Disclosure Act’s
definitions of “lobbying activities” and “lobbying contacts” exclude, and do not
independently apply to activities which consist only of “grass roots” lobbying and
public advocacy.14
Similarly, since the term “lobbying activities” relates only to the direct lobbying
of covered federal officials, the “Simpson Amendment” would not appear to limit in
any way an organization’s use of its own private resources to lobby State or local
legislators or other State of local governmental bodies or units. While direct
lobbying of the Congress, or of certain high level executive branch officials, is
covered under the Lobbying Disclosure Act as a “lobbying contact,” and thus by
definition a “lobbying activity,” the acts of testifying before a congressional
committee, subcommittee, or task force, or of submitting written testimony for
inclusion in the public record of any such body, or of responding to notices in the
Federal Register or other such publication soliciting communications from the public
9 See comments by the sponsors of provision, Senator Simpson and Senator Craig, at
141 Congressional Record S10547, S10556, July 24, 1995 (daily ed.).
10 141 Congressional Record, supra at S10555 (Senator Simpson).
11 2 U.S.C. § 1602(7), P.L. 104-65, Section 3(7).
12 2 U.S.C. § 1602(8), P.L. 104-65, Section 3(8).
1 3 Note this express exception to the term “lobbying contact,” at 2 U.S.C. §
1602(8)(B)(iii), P.L. 104-65, Section 3(8)(B)(iii).
14 Broader limitations on public advocacy and lobbying by organizations receiving
federal grant money, and on entities wishing to do business with federal grantees, which had
passed the House as appropriations riders in the 104th Congress (commonly known as the
“Istook Amendment,” e.g., H.R. 2127, 104th Congress, H.J. Res. 114, 104th Congress), have
not as of this writing been enacted into law.
CRS-5
to an agency, are expressly exempt from the definition of a “lobbying contact,” and
thus in themselves can not qualify as a “lobbying activity.”15
Restrictions on Use of Federal Funds Generally. Broad prohibitions on the
use of federal monies for lobbying or political activities have been in force for a
number of years. Express restrictions on the use of grant funds by non-profit
organizations were adopted in 1984 as part of uniform cost principles for non-profit
organizations issued by the Office of Management and Budget (OMB) in OMB
Circular A-122, and are now incorporated into the Federal Acquisition Regulations.
Under current federal provisions, no contractor or grantee of the federal government,
regardless of tax status, may be reimbursed out of federal contract or grant money for
their lobbying activities, or for political activities, unless authorized by Congress.16
These restrictions generally apply to attempts to influence any federal or State
legislation through direct or “grass roots” lobbying campaigns, political campaign
contributions or expenditures, but exempt any activity authorized by Congress, or
when providing technical and/or factual information related to the performance of a
grant or contract when in response to a documented request.
In addition to these restrictions of general applicability on the use of federal
contract or grant money for lobbying activities, there may be specific statutory
limitations and prohibitions on particular federal moneys or on particular federal
programs. Appropriation riders, for example, may also expressly limit the use o
17
f
federal monies appropriated in a particular appropriations law for lobbying, or
“publicity or propaganda” campaigns directed at Congress by private grant or
contract recipients.18
Under the provisions of federal law commonly referred to as the “Byrd
Amendment,” federal grantees, contractors, recipients of federal loans or those with
cooperative agreements with the federal government, are expressly prohibited by law
from using federal monies to “lobby” the Congress, federal agencies, or their
employees, with respect to the awarding of federal contracts, the making of any
grants or loans, the entering into cooperative agreements, or the extension,
modification or renewal of these types of awards. 31 U.S.C. § 1352(a). Federal
contractors, grantees and those receiving federal loans and cooperative agreements
15 See 2 U.S.C. 1602(8)(B), P.L. 104-65, Section 3(8)(B) for list of 18 express
exceptions to the term “lobbying contacts.”
16 See Federal Acquisition Regulations (FAR) 48 C.F.R. §§ 31.205-22; 31.701 et seq.;
drafted to encompass the principles set out in OMB Circular A-122, ¶B21, as added 49 F.R.
18276 (1984).
17 See, for example, 42 U.S.C. § 2996(f)(a)(5), re grantees and contractors of the Legal
Services Corporation.
1 8 Note discussion of anti-lobbying appropriations provisions and grant funds in
General Accounting Office, Principles of Federal Appropriations Law, Second Edition, at
4-179 to 4-184 (July 1991). It should be noted that the federal criminal statutory provision
on lobbying with appropriated monies, 18 U.S.C. § 1913, applies only to federal officers and
employees, and not to the private recipients of federal grants, contracts or other federal
disbursements. See Grassly v. Legal Services Corporation, 535 F. Supp. 818, 826, n.6 (S.D.
Iowa 1982).
CRS-6
must also report lobbying expenditures from non-federal sources which they used to
obtain such federal program monies or contracts. 31 U.S.C. § 1352(b). Agencies of
the federal government which administer loans, grants and cooperative agreements
have issued common regulations implementing the “Byrd Amendment.” Th
19
e
restrictions of the “Byrd Amendment” apply to the making, with an intent to
influence, any communication to or appearances before Congress or an agency on a
covered matter. Any “information specifically requested by an agency or Congress
is allowable at any time” (56 F.R. 6739), and certain other contacts are allowable
depending on the timing and nature of the communication with respect to a particular
solicitation for a federal grant, contract or agreement.
Lobbying Disclosure Requirements for Non-Profit Organizations
Organizations which engage in a certain amount of lobbying activities through
personnel compensated to lobby on the organization’s behalf, will be required to
register and to file disclosure reports under the new Lobbying Disclosure Act of
1995.2 There is no general exclusion or exception from the disclosure an
0
d
registration requirements for non-profit organizations who otherwise meet the
threshold requirements on lobbying contacts, except for churches and their integrated
auxiliaries which are exempt from reporting and disclosure.21
The Lobbying Disclosure Act of 1995 was intended to reach so-called
“professional lobbyists,” that is, those who are compensated to engage in lobbying
activities on behalf of an employer or on behalf of a client. When registration i
22
s
required for organizations which lobby, such registration is done by the organization,
however, rather than by the individual employee/lobbyist. That is, the organization
which has employees who qualify as lobbyists for the organization (in-house
lobbyists), must register and identify its employee/lobbyists.
An organization will be required to register its employee/lobbyists when it meets
two general conditions. First, it must have one or more compensated employees who
engage in “lobbying,” that is, who make more than one “lobbying contact,” and who
spend at least 20% of their total time for that employer on “lobbying activities,” over
19 Note 55 F.R. 6735-6756 (February 26, 1990).
20 P.L. 104-65, December 19, 1995, 109 Stat. 691. In 1995 Congress completely
rewrote the 50-year old law (the Federal Regulation of Lobbying Act of 1946) which had
required certain registrations and disclosures of lobbying activities directed at Members of
Congress. Beginning in 1996, the new Lobbying Disclosure Act of 1995 will provide more
specific thresholds, and clearer and broader definitions of “lobbyist” and “lobbying
activities,” which will trigger the requirements for the registration and reporting of persons
who are compensated to engage in lobbying activities.
2 1 See exemptions from definition of covered “lobbying contact,” 2 U.S.C. §
1602(8)(B)(xviii), for churches and religious orders that are exempt from filing federal
income tax returns under 26 U.S.C. § 6033(a)(2)(A).
22 See H.R. Rpt. 104-339, 104th Cong., 1 Sess., “Lobbying Disclosure Act of 1995,”
st
at 2 (1995).
CRS-7
a six month reporting period. A “lobbying contact” is an oral or writte
23
n
communication to a covered official, including a Member of Congress, congressional
staff, and certain senior executive branch officials, with respect to the formulation,
modification or adoption of a federal law, rule, regulation or policy. The term
“lobbying activities” is broader than “lobbying contacts,” and includes “lobbying
contacts” as well as background activities and other efforts in support of such
lobbying contacts.
Secondly, for an organization to register its lobbyist/employees, the organization
must have spent, in total expenses for lobbying activities, $20,000 or more in a six-
month reporting period.24 The $20,000 amount will include any money paid to an
outside lobbyist to lobby on the organization’s behalf during the reporting period.25
Under the Act a “lobbyist” needs to be registered within 45 days after first
making a lobbying contact or being employed to make such a contact. Registration
will be on identical forms filed with the Secretary of the Senate and Clerk of the
House. The information on the registrations will generally include identification of
the lobbyist, the employer or the client, and any organizations other than the client
that contribute more than $10,000 for the lobbying activities in six months and plays
a major role in supervising or controlling the lobbying activities; an identification of
any foreign entity that owns 20% of the client, controls the activities of the client or
is an interested affiliate of the client; a list of the issues in which the lobbyist is
interested, and those on which he or she has already lobbied for the client or
employer. In addition to the registration of lobbyists, semi-annual reports, covering
January 1 - June 30, and July 1 - December 31, are required to be filed. These reports
will identify the lobbyist, clients and employers, and issues upon which one lobbied,
and the reports are to provide a good faith estimate of lobbying costs, rounded to the
nearest $20,000 (if expenses exceed $10,000).
Certain public charities will have the option of using the Internal Revenue Code
definitions of “influencing legislation” rather than the Lobbying Disclosure Act
definitions of “lobbying activities” to determine the organization’s reporting
obligations. This option was provided so that such organizations would only need
26
to have one set of internal record controls and standards dealing with “influencing
legislation,” under both the tax code and the Lobbying Disclosure Act of 1995.27
Since the definition of “influencing legislation” under the Tax Code, and the
definition of “lobbying activities” under the Lobbying Disclosure Act are different,
an eligible organization may need to decide which definition is more advantageous
23 2 U.S.C. § 1602(10).
24 2 U.S.C. § 1603(a)(3).
25 An outside lobbyist needs to register for a particular client if its total income from
that client for lobbying related matters exceeds $5,000 in a six month filing period.
26 2 U.S.C. § 1610.
27 H.R. Rpt. No. 104-339, supra at 23.
CRS-8
to use, from both a tax standpoint, as well as in relation to its planned public policy
activities.28
In addition to covering only those who are hired or retained to lobby, the
provisions of the Lobbying Disclosure Act of 1995 cover as a threshold only
activities which may be described as “direct” lobbying, that is, direct
communications or contacts with covered officials. The registration and disclosure
requirements of the law are not separately triggered by “grass roots” lobbying by
persons or organizations. That is, an organization or entity which engages only in
grassroots lobbying, regardless of the amount of “grass roots” lobbying activities,
will not be required to register its members, officers or employees who engage in
such activities. Once qualified or covered as a lobbyist, however, grass root
29
s
lobbying efforts and other background activities which support direct “lobbying
contacts” may have to be disclosed as “lobbying activities.”
The Lobbying Disclosure Act also exempts from the definition of “lobbying
contacts” the activities of lobbying State or local legislators or other State or local
governmental bodies or units. While direct lobbying of the Congress, or of certain
high level executive branch officials, is covered under the Lobbying Disclosure Act
as a “lobbying contact,” the acts of testifying before a congressional committee,
subcommittee, or task force, or of submitting written testimony for inclusion in the
public record of any such body, or of responding to notices in the Federal Register
or other such publication soliciting communications from the public to an agency, are
expressly exempt from the definition of a “lobbying contact,” and thus in themselves
can not qualify as a “lobbying activity.”30
Additional Reading
Robert A. Boisture, for Independent Sector, “What Charities Need to Know To
Comply With the Lobbying Disclosure Act of 1995,” in Complying With the
Lobbying Disclosure Act of ‘95 and the New Gift Act Restrictions 185-208 (Glasser
Legal Works 1996).
Comment, “Guiding Lobbying Charities Into A Safe Harbor: Final Section
501(h) and 4911 Regulations Set Limits for Tax-Exempt Organizations,” 61 Miss.
L.J. 157 (Spring 1991).
2 8 For detailed discussions of several considerations and factors, see Richard L.
Winston, “The Lobbying Disclosure Act of 1995 and the Tax Code Elections,” Tax Notes,
1391-1399 (June 3, 1996); Robert A. Boisture, for Independent Sector, “What Charities
Need to Know To Comply With the Lobbying Disclosure Act of 1995,” in Complying With
the Lobbying Disclosure Act of ‘95 and the New Gift Act Restrictions, 185-208 (Glasser
Legal Works, 1996).
29 Specifically excluded is any communication “made in a speech, article, publication
or other material that is distributed and made available to the public, or through radio,
television, cable television, or other medium of mass communication.” 2 U.S.C. §
1602((8)(B)(iii).
30 See 2 U.S.C. 1602(8)(B), P.L. 104-65, Section 3(8)(B) for list of 18 express
exceptions to the term “lobbying contacts.”
CRS-9
Bruce H. Hopkins, The Law of Tax-Exempt Organizations, Sixth Edition
(1992)(1995 Cumulative Supplement).
Bruce R. Hopkins, Charity, Advocacy and the Law (1992).
Richard L. Winston, “The Lobbying Disclosure Act of 1995 and the Tax Code
Elections,” Tax Notes, 1391-1399 (June 3, 1996).
CRS Reports
CRS Report 96-264. Frequently Asked Questions About Tax-Exempt Organizations,
by Marie B. Morris and Felicia Kolp.
CRS Report 96-210. Legal and Congressional Ethics Standards of Relevance to
Those Who Lobby Congress, by Jack Maskell.