I will reach out to our auditors for their advice. They understand and apply IRS regulations every day.
As I think about this, irrespective of acting as an individual or not, the problem lies when you draw a line from a donation back to ARRL. If you like a candidate, that’s just fine. If it is clear that a donation, or a sudden influx of
donations, represents a veiled action by ARRL and its Directors, I imagine that could be a problem.
On a personal note, I suspect it would be viewed as going 60 in a 55. There isn’t much money or influence going on here. But I’ll leave it to CohnReznick to give appropriate guidance.
You should also know that we have, even very recently, been asked by members to divulge the political affiliations of our board, by director. Once you start writing checks to candidates within the realm of ARRL, that’s going to become
transparent and real.
David
From: arrl-odv <arrl-odv-bounces@reflector.arrl.org>
On Behalf Of Michael Ritz
Sent: Sunday, October 15, 2023 9:51 PM
To: arrl-odv@reflector.arrl.org
Subject: [arrl-odv:35259] Re: Cruz & Johnson
It looks like as long as Roderick or Minster are not involved, as the "executive Directors", it's probably OK....
"If an organization’s executive director promotes or opposes one candidate over another while in his or her official capacity, the organization’s status will
likewise be jeopardized. However, board directors, members, and staff are free to express their support for or opposition to a candidate in their private capacities.Though your organization
can’t specifically endorse a candidate, you can still contribute in the field of politics. Many segments of the US population have benefited in the past when nonprofits have provided non-partisan support to registration drives, voter education programs, and
candidate debates. The critical thing to remember in these cases is to stay outside the fray, remaining objective as an organization.For more information regarding the Johnson Amendment and how it applies to your organization, visit
IRS.gov. Or be sure to visit
ExemptMeNow for the latest updates pertaining to tax exemption and non-profit news."
Perhaps a distinction can be made in how a "contribution" is made payable. John mentions making a contribution payable to a "campaign" but another possibility is to a PAC (which
is what I've seen done before).
We've had the issue of this political line come up periodically over the years and I'm glad Mark sent out the article from Sumner as a reminder. It appears there is a hard line
against any involvement in a political campaign so we need to careful and not give some critic an issue.
While I very much appreciate the effort that John and others put into getting this level of access, I am very uncomfortable with giving so-called personal donations
in this fashion. I’m particularly uncomfortable with them being solicited on this ARRL hosted email list. I think an outside legal opinion is needed, at a minimum.
All
We have a 10.20.23 in-person meeting with Sen. Ted Cruz at his Houston office. We will have multiple, local AR reps in the meeting, including at least one elected office holder. The purpose of the meeting is to persuade Sen.Cruz to be our lead Senate sponsor.
We also have a 10.24.23 dinner in DC with Cong. Bill Johnson and one other Congressman.
It would be beneficial to our cause if we were to tender contributions to their campaigns. I will be tendering contributions to both.
We are advised that $250 and up are reasonable contributions. If you can't hit that mark, any contribution would be beneficial. These contributions MUST be individual, non-corporate donations — and NO — any contribution cannot be reimbursed from your Director's
budget. No contribution is too small.
If you wish to contribute to either Johnson or Cruz, you may make your check payable to "Bill Johnson Campaign" or "Ted Cruz Campaign" and send them to me. I will see to it that our lobbyists deliver your donations along with mine to the appropriate campaign
person.
_______________________________________
John Robert Stratton
N5AUS
Director
West Gulf Division
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-Kristen (K6WX)
"Your eyes ... it's a day's work just looking into them"
Laurie Anderson
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