Political Tax and Tax Exempt Organizations

Covington regularly advises Section 527 political organizations and other tax-exempt and not-for-profit organizations -- as well as individual directors, officers and fiduciaries -- in a wide variety of sophisticated tax matters specific to entities participating in the electoral process. Our work in this area includes both advising on the creation and operation of such organizations to ensure they are in compliance with the applicable laws and representing clients before the Internal Revenue Service. We have particular expertise in issues relating to the ability of 501(c)(4) social welfare organizations and 501(c)(6) trade associations to engage in permissible election activities, and in issues relating to affiliations among tax-exempt entities, such as affiliated groups consisting of 501(c)(3) charitable, social welfare and Section 527 organizations. We also regularly counsel clients on the restrictions on legislative activities, public disclosure requirements, the unrelated business income tax and the income tax imposed on 501(c) organizations that engage in taxable political activities.