Subject: Re: IRS guidance on political activity
From: <[email-masked]>
To: "Mark H. Gitenstein" <[email-masked]>, "john mcgrail" <[email-masked]>
Cc: "Steve Ricchetti" <[email-masked]>, "Hunter Biden" <[email-masked]>, "Alex Snyder-Mackler" <[email-masked]>
Date: Fri, 15 Jan 2016 13:35:59 +0000 (UTC)

Thanks

Sent from Xfinity Connec= Mobile App

------ Original Message ------

john mcgrail
To: Mark Gitenstein, Ted Kaufman
Cc= Steve Ricchetti, Hunter Biden, Alex Snyder-Mackler
Sent: Ja=uary 14, 2016 at 8:25 PM
Subject: Re: IRS guidance on political =ctivity

Cato and =Heritage are (c)(3)s.  Democracy Corps is a (c)(4), which mean= their donors do not get a tax deduction.

CAP is a (c)(3) but has an affiliated (c)(4).

=rom: "Gitenstein, Mark H." <MGitenstein@mayerbrown=com>
To: "ted=[email-masked]" <[email-masked]>; John McGrail <=[email-masked]>
Cc: Steve Ricchetti <[email-masked]>; Hunter Biden <hbide=@rosemontseneca.com>; Alex Snyder-Mackler <[email-masked]> Sent: Thursday, January=14, 2016 12:05 PM
Subject: RE: IRS guidance on political activity

=emocracy Corps advertises itself as a non-profit but actually I’m no= sure that its (c) (3) or (4).  See this

https://secure.actblue.com/contribute/page/demcorps?refcode=email&rec=rring=12.  Note that it makes it clear that contributions to De=ocracy Corps are NOT tax exempt.  We may need Bauer’s advice on=this .  I’ll also check with my tax exempt guy.  I tried
to access Democracy Corps 990 but had trouble accessing it.
=20

Privileged & Confidential

Work Product

&n=sp;

&n=sp;

&n=sp;

Mar= Gitenstein

Mayer Brown LLP

199= K st NW

Was=ington, DC, 20006-1101

+12=2-263-3371

&n=sp;

From: [email-masked] [mailto:[email-masked]]

Sent: Thursday, January 14, 2016 11:26 AM

To: John McGrail

Cc: Steve Ricchetti; Hunter Biden; Alex Snyder-Mackler; Gitenstein, =ark H.

Subject: Re: IRS guidance on political activity

I assume the demo=racy corps, Cato institute, and heritage foundation are 501c3's? Right=

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------ Original Message ------

From: John McGrail

To: Ted Kaufman

Cc: Alex Snyder-Mackler, Steve Ricchetti, Mark Gitenstein, Hunter Biden

Sent: January 14, 2016 at 10:08 AM

Subject: IRS guidance on political activity

A tax-exempt 501(c)(4) must be operated exclusively to promote social welfa=e. "The promotion of social welfare does not include direct or indire=t participation or intervention in political campaigns on behalf=of or in opposition to any candidate for public
office. However, a section 501(c)(4) social welfare organization may engag= in some political activities, so long as that is not its primary activity="

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