Overlapping Public Disclosure Requirements Can Be Complicated
June 5, 2013
Much controversy attends the ability of tax exempt 501(c)(4) social welfare organizations to make expenditures in connection with candidates in U.S. elections. We’ll spare you the links. Since Citizens United, new public disclosure requirements have been sought and, in places, implemented for these and other corporations engaged in political spending. To illustrate our topic, we look at the public disclosure requirements that apply in this year’s New York City elections. Consider the following hypothetical expenditure:
- An employee of a 501(c)(4) organization uses office resources and supplies to produce flyers to expressly support the election of a candidate for New York City Council. She distributes those flyers as she collects signatures on ballot petitions as a volunteer for that same candidate.