Political Activity Guidelines for
Catholic Organizations

15 March 2004
The following document is provided by the USCCB Office of General Counsel in order to assist (arch)dioceses, parishes, and other Catholic organizations (“Catholic organizations”) that are exempt from federal income tax under section 501(c)(3) of the Internal Revenue Code (“IRC”) in distinguishing activities that are permitted during election campaigns from activities that are prohibited. This guidance focuses primarily on section 501(c)(3) of the IRC, because it contains a prohibition, which has been interpreted as absolute, against participation or intervention in a political campaign on behalf of or in opposition to any candidate, as a condition of maintaining federal income tax exemption.

General guidance cannot anticipate every conceivable fact pattern. Nor can it substitute for the advice Catholic organizations should receive from their own attorneys, because application of the political campaign activity prohibition is inherently fact-specific and frequently presents close questions. An (arch)diocese or parish with questions about a particular activity should contact its (arch)diocesan attorney prior to engaging in that activity. Other Catholic organizations should contact their own legal advisors.

Table of Contents

Political Campaign Activity Prohibition

Lobbying Limitation

Origins of the Political Campaign Activity Prohibition

First Amendment Considerations

Lobbying v. Political Campaign Activity

Legislation

Ballot Measures

Lobbying Election

Individual Political Campaign Activity

Attribution of Individual Activity

Candidate

Public Office

Activities Prohibited

Specific Situations

Appearances at Church Events

Bumper Stickers

Campaign Materials

Collecting Signatures

Columnists

De Minimis Activity

Educating Candidates

Educating Voters

Endorsements, Statements of Opposition

Financial Support

Fundraising

Letters to Editor

Loans

In-Kind Support

Internet Activities

Issue Advocacy

Mailing Lists

News Stories

PACs

Paid Political Advertising

Parking Lots

Photo Ops

Polling Places

Public Forums, Debates, Candidate Nights

Pulpit Appearances

Rating Candidates

Renting Facilities

Signs on Church Property

Student Activities

Voter Guides – Candidate Questionnaires

Voter Guides – Incumbents Voting Records

Voter Registration, Get-Out-the-Vote Drives

Websites

Enforcement

Targeting

FECA, Other Laws

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What does section 501(c)(3) of the IRC say about political campaign activity? Section 501(c)(3) of the IRC prohibits organizations that are exempt from federal income tax under its provisions, including Catholic organizations exempt under the USCCB Group Ruling, from participating or intervening in political campaigns on behalf of or in opposition to any candidate for public office. As noted, this prohibition has been interpreted as absolute.

How does the IRC limit lobbying activity by Catholic organizations? The IRC limits the amount of lobbying in which ...

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