CHAPTER 7
Labor, Agricultural, and Horticultural Organizations: §501(c)(5)

Internal Revenue Code (IRC) §501(c)(5) encompasses three specific kinds of organizations: labor unions, agricultural groups, and horticultural groups. These groups are distinguishable from those classified as business leagues partly because their members may represent a range of pursuits rather than a narrow “line of business” as required under (c)(6). An organization qualifying under this category may now allow its net earnings to inure to the private benefit of any member, although a labor union can provide some individual benefits.1 Comparatively, the inurement provision applied to (c)(3) and (c)(4) organizations applies to those who are in a position to control the organization.2 On a positive note, the intermediate sanction penalties are not imposed on members of a (c)(5) organization that receive impermissible benefits.3 These worker-oriented groups may serve only the three purposes provided in regulations that have not been revised since 1958:

  1. Betterment of conditions of those engaged in such pursuit.
  2. Improvement of the grade of their products.
  3. Development of a high degree of efficiency in their respective occupations.4

7.1 Labor Unions

The Internal Revenue Service (IRS) defines a labor organization as an “association of workers who join together to protect or promote the interests of the members by bargaining collectively with their employers to secure better working conditions, wages, and similar benefits.”5 The term includes labor unions, councils, and committees.6 It is not mandatory that the membership be exclusively employees, though the character of revenue received from nonmembers might be treated differently.7 The purpose for which the nonprofit is formed determines exempt status.

(a) Organizational Structure and Documents

The Internal Revenue Code and Regulations impose no requirements regarding organizational structure. Form 1024, however, imposes a very clear organization test: “If the organization does not have an organizing instrument, it will not qualify for exempt status. The bylaws of an organization alone are not an organizing instrument. They are merely the internal rules and regulations of the organization.” IRS Publication 557, Tax Exempt Status for your Organization,8 makes the following suggestion to enable a proposed union to achieve recognition of its exempt status:

To show that your organization has the purpose of a labor organization, you should include in the articles of organization or accompanying statement (submitted with your exemption application) information establishing that the organization is organized to better the conditions of workers, improve the grade of their products, and develop a higher degree of efficiency in their respective occupations.

(b) Scope of Activities

Promoting and protecting the interests of workers can be accomplished in a variety of ways. Labor unions whose activities are limited to representing employee members can readily be granted exemption. Some peripheral activities may also allow a workers' organization to qualify under the labor organization classification. Examples of permissible activities include the following:

  • Improvement of professional abilities of members through seminars, courses, and participation in conventions; securing better salaries and working conditions for workers through collective bargaining and processing grievance procedures.9
  • Worker dispatch systems to provide equitable allocation of available work and to adjudicate and settle grievances.10
  • Provision of strike benefits11 and mutual death, sickness, accident, and similar benefits for union members only (from member-contributed funds),12 but not accounting and tax services.13
  • Apprenticeship committees with union and employer representatives to establish standards of employment and qualification in skilled crafts, and to arbitrate in apprentice–employer disputes.14
  • A nurses' association established to bargain collectively with health institutions.15
  • Seminars and training programs, newspapers,16 conventions, and legal defense and litigation activities17 by individual unions or associations of labor organizations and unions.
  • Labor “temples” or centers containing offices, meeting and recreation halls, and a barbershop, and otherwise providing a home to 162 unions, and which are owned by the unions.18
  • An employee welfare benefit plan established under the terms of a collective bargaining agreement to provide training for workers was allowed to expand its programs to include a scholarship plan to provide training and reimbursement for lost wages when they took time off for training.19

(c) Non-(c)(5) Activities

Activities outside the historical role of unions may not be conducted as a primary purpose of a (c)(5) organization. A qualifying labor union cannot, as its primary activity, receive, hold, invest, distribute, or otherwise manage funds associated with savings or investment plans or programs, including pension or other retirement savings plans.20 Whether the union itself, a directly affiliated organization, or a totally separate group undertakes the activity can be determinative. The IRS has generally allowed unions to have concerns other than wages, working hours, and working conditions, but only when they are mutually beneficial to union members. Among the activities that have resulted in denial of union status are:

  • Savings plans for individual members established under a collective bargaining agreement to collect money and disburse it annually to members, and unrelated to strikes or wage levels.21
  • Businesses formed to provide employment for members.22 The fact that the profits from such a business go to a union does not help.
  • An association formed to collect and pay over federal and state employment taxes on behalf of a group of manufacturers.23
  • An organization formed by individuals (not by a union) to pay weekly income to workers in the event of a strike called by the members' union, but not to represent the workers in employment matters, does not qualify.24 But a labor union's provision of financial assistance to its members during a strike is an exempt activity.25
  • Unions of individual business owners.26

A labor organization that primarily conducts exempt functions may also have a limited amount of unrelated business activity without necessarily losing its exempt status.27

(d) Political Activities

There is no specific guideline limiting the extent of lobbying and other attempts to influence legislation permitted for a (c)(5) organization. The IRS says some germane lobbying activity relating to labor union concerns is acceptable, but should not become the organization's primary activity.28 An organization that spends more than half the annual budget on lobbying might find its exempt status challenged.

Campaigning on behalf of candidates for public office is not specifically prohibited, as it is for organizations exempt under §501(c)(3).29 However, campaigning30 cannot be a primary purpose. Funds expended in efforts to influence elections, to the extent of the organization's investment income, are taxable under IRC §527. A segregated fund could be created to clearly delineate the activity and its income from the union's other sources of funds. Importantly, there are also limitations on political activity imposed by federal and state election laws.

(e) Membership

Membership in a labor organization traditionally includes employees, employers, and others whose participation in the union is to advance a focused field of work, including autoworkers, pipefitters, or teachers, for example. To qualify for tax exemption, a union must be an association of workers formed to seek better working conditions, wages, and similar benefits.31 When the union has membership classes for persons not directly involved in its type of work, two related, but different, questions arise. The first issue is qualification for tax exemption: the union must show that it operates to benefit workers. A nurses' association32 and a plumbers' group33 composed mostly of employees were allowed to qualify even though a limited number of their members were independent contractors working in the field. If, instead, most of the members are independent contractors, exemption must be sought under IRC §501(c)(6) as a business league.34

A union with associate membership classes also faces a question of character for the revenues paid by its members. The IRS once insisted that membership denotes a formal relationship in which a person, whether specifically described as a member or not, has specific rights and obligations. Dues paid by nonvoting associate members represented unrelated business income in the IRS's eyes. Unions and the IRS fought about this question for some years, as described here for historical context.

To clarify the issue, the IRS issued formal guidance in 1995.35 A primary purpose test was provided, which asks, “Is the associate member category created and used to further the organization's exempt purposes or simply to produce unrelated income?” Further, in applying this principle, “the Service looks to the purposes and activities of the organization rather than of its members.” The IRS noted in the guidance that (c)(5) organizations often receive dues payments not only from members who are accorded full privileges in voting but also from associate members who are given less than full, or no, voting privileges. The IRS said it would not treat associate member dues as unrelated business income unless the facts indicate the membership category was created to produce unrelated income.

Membership categories for students studying in the field and retired persons should not be questionable in this regard, nor should layers of membership according to years of service or amount of compensation. Note that Congress chose not to give unions the special exception36 given to agricultural groups that automatically exempts a portion of the dues from classification as unrelated business income. Labor unions must be alert to documenting the purpose of creating various membership classes.

Two cases involving insurance plans administered by the Office of Personnel Management through the Federal Employee Health Benefits Act (FEHBA) provide some insight into this issue. The first case involved the American Postal Workers Union (APWU).37 The IRS took the position that a portion of the associate (nonpostal worker) member dues was attributable to the group health insurance plan and thereby produced unrelated business income, essentially saying that associate member concerns were unrelated to the basic purpose of serving postal worker members. Thus, the IRS assessed unrelated business income tax on the profits from the associate member group insurance.

After reviewing the charter and bylaws of the union, the district court found that the APWU was organized to serve not only postal workers but any classified federal employee. Its membership was not limited to those employed by the U.S. Postal Service. This broad scope of coverage for all federal employees is permissible under the §501(c)(5) regulations pertaining to labor unions, which state that “a labor union is a voluntary association of workers that is organized to pursue common economic and social interests.” Any union is free to define its constituents. Furthermore, the court found that there were “no requirements in the Internal Revenue Code that a union member receive any particular quantum of benefit in order to be considered a bona fide member.” Likewise, the court found that the IRS's position that members had to have the right to vote was wholly without authority.

The court decided that the APWU's sponsorship of a group insurance plan served an exempt purpose as a mutual benefit organization. The court also found that the insurance program was not undertaken to make a profit, and that “providing economic benefits to members in return for dues is not a trade or business,” citing the 1921 Congressional Record.

The appeals court, however, disagreed and found that the provision of insurance to nonpostal workers was not related to the union's stated focus on the interests of postal employees. The judge admitted that the case was difficult because nothing in the regulations or any other authoritative source defined the exempt purposes of a labor union. However, based on a review of the organization's constitution, the court found that privileges of membership were granted only to active members, and that provision of insurance benefits to nonmembers could not be substantially related to the union's exempt purpose. The court was also swayed by the substantial profit generated by nonmember fees.

In a somewhat similar case, the Court of Claims decided that the National Association of Postal Supervisors' (NAPS) health insurance activity was taxable, because this was an unrelated trade or business operated to produce a profit and was in competition with taxable insurance providers.38 The NAPS case facts were distinguishable from those in the APWU case in one important respect: The NAPS court decided that the associate members were not members. The nonpostal employee members were called “limited members.” Their dues were calculated to produce a profit, they did not participate in other union programs, and their memberships were dropped if they failed to continue coverage in the health plan. Although it was not stated, perhaps the deciding factor in the NAPS case was the fact that within five years of starting the insurance program, the limited-benefit members made up 71 percent of the total number of members in the plan. Thus, the facts supported the IRS's position that the insurance program's purpose was primarily to produce profit, not to serve members. Yet another postal union was made to pay tax on its insurance program because the court found that “providing insurance to persons who are not members in any other sense” cannot be substantially related to the union's exempt purpose.39

7.2 Agricultural Groups

Agricultural associations are subject to the same basic requirements and constraints outlined previously for labor groups. Again, the code, regulations, and IRS Handbook are silent about the form of organization. In practice and for purposes of filing Form 1024, organizational documents must be adopted to establish governance rules and prohibit private inurement. The purpose must reflect that the organization is devoted to techniques of production, betterment of conditions to those engaged in agriculture or horticulture, development of efficiency, or improvement of the grade of products. Members of a qualifying agricultural group need not necessarily all be farmers.40

An agricultural entity often conducts programs that could qualify as charitable, such as conducting programs that educate members on saving crops during drought conditions or provide aid to distressed members. To seek funding, such a group might consider forming a §501(c)(3) entity to conduct such programs. One private ruling indicated the careful balance that must be maintained between programs conducted by the affiliated charity and the agricultural group. After a thorough review of resources and expenditures in one instance, the IRS found that the proposed entity did not qualify for charitable exemption because a majority of its expenses would be spent for member meetings and social events; the IRS declared that these promoted the cattle industry.41

An organization operated to promote the dairy industry's acceptance of registered “DBreed” due to the breed's genetic and economic contribution sought reclassification of its IRC §501(c)(5) status to IRC §501(c)(3). Though its magazine, exhibitions, and scholarships have an educational component, these programs were deemed insubstantial in relation to activities conducted to promote the DBreed for the economic benefits of its members and therefore precluded exemption under §501(c)(3).42

(a) Types of Crops

The IRS Exempt Organizations Handbook separately defines agriculture on the land and on the sea because, until 1976, aquaculture was excluded. The handbook first defines agriculture to include “the art and science of cultivating the ground, especially in fields or large quantities, including the preparation of the soil, planting of seeds, raising and harvesting of crops, and rearing, feeding, and management of livestock, that is tillage, husbandry, and farming.”43

Next, it explains that IRC §501(g), added in 1976, includes the “harvesting of aquatic resources” and says that Congress now intends agriculture to include fishing and related pursuits such as the taking of lobsters and shrimp. Both freshwater and saltwater occupations are to qualify, along with the cultivation of underwater vegetation, such as edible sea plants. Finally, the handbook says that agriculture includes the “cultivation of any edible organism.” In addition to cattle, crops, and fish, fur-bearing animals and their pelts44 have also been ruled to be agricultural products. An association formed to guard the purity of the Welsh pony breed qualified.45

The category of agricultural products was found not include the following:

  • Mineral resources, such as limestone. (But what about minerals used in vitamin supplements for human consumption?)
  • Dogs not used as farm animals.46
  • Horse racing, despite the fact that the horses are raised on a farm (unless the racing is a part of an agricultural fair and stock show).47
  • Harvesting brine shrimp cysts, which was not considered farming.48

A broad range of activities associated with and supportive of agriculture may qualify under this category. The organization itself need not be directly involved in cultivation. Examples of agricultural groups that the IRS views as exempt include:

  • State and county farm bureaus.49
  • Promoters of artificial insemination of cattle.50
  • A group to study aquatic harvesting of seaweed or organic gardening.
  • A crop seed certification/seed technology research group.51
  • A rodeo sponsor.52
  • An association of farmers' wives.53
  • A producers' association formed to negotiate crop prices (but not to market the crops as a sales agent).54

(b) Services to Members

A qualifying agricultural organization must not allow its net assets to benefit its individual members. Providing a direct business service for the economic benefit of members cannot be the primary purpose of an agricultural group. The rules generally place more constraints on agricultural groups than on unions. Activities that the IRS has deemed to convey such benefits, rather than advancing the “betterment of conditions of those engaged in agriculture,”55 and which are therefore not appropriate activities for an exempt agricultural association, include:

  • Management, grazing, and sale of members' cattle.56
  • A housing and labor pool for transient workers.57
  • Cooperative marketing of products (as opposed to monitoring or controlling pricing).58
  • Leasing a facility to weigh, sort, grade, and ship livestock.59
  • A butter and cheese manufacturers' institute (because butter is an agricultural byproduct—milk is the agricultural product).60
  • Provision of welfare aid and financial assistance to members.61
  • Acting as sales agent for members rather than representing members in negotiating prices with processors.62
  • Operating and promoting a farmers' market for produce, prepared foods, and crafts of local farmers was deemed a business service for the economic benefit of the members and not a qualifying exempt activity for an agricultural group under IRC §501(c)(5). The bylaws state that all items are sold for the benefit of both consumers and producers, to stimulate economic growth and a greater variety of farm and home industry activities and products, and to educate the public in the value of these products and activities.63 Thus, the IRS decided that the activity was “not aimed at the overall betterment of conditions within the farming industry,” but instead provided a venue for members to promote and sell their goods for private benefit.

The rental of an agricultural association's fairground facilities for that portion of the year the spaces were not used for its own annual fair was a mini-storage business in the eyes of the IRS.64

To better illustrate the distinction between service to members and advancement of the industry, compare a producers' group formed to process production data for its members' use in improving their herds' milk production65 with a nationwide organization that gathers milk production statistics for the U.S. Department of Agriculture.66 The former group was not granted exemption because it relieved the individual farmers of work they would have had to perform themselves and did not necessarily improve the conditions of the milk industry.

Educational programs to promote farm cooperatives, information regarding economic and social conditions for farmers, information about farm products, youth camp sponsorships, newsletter publication, and other services were found by the Tax Court to be conducted by a statewide federation of local county farm bureaus for exempt purposes.67 The fact that the services provided to the member cooperatives were “not directly proportional to the amount of the fees paid”68 also indicated that individual economic benefits were not directly tied to the payments.

(c) Special Exception

Agricultural or horticultural organizations gained a special exception from allocation of portions of their members' dues as unrelated business income.69 The IRS has been aggressive and successful in treating the associate member dues collected by unions from nonunion members as unrelated business income.70 Effective retroactively for taxable years beginning after December 31, 1986, agricultural groups were afforded special protection from such a position for required annual member dues of up to $100 ($160 for 201571; $158 for 201472; $151 for 2012; $145 for 2010–2008; $136 for 2007; $131 for 2006; $127 for 2005). This special provision in §512(d) says

If an agricultural or horticultural organization described in section 501(c)(5) requires annual dues to be paid in order to be a member of such organization, and the amount of such required annual dues does not exceed $100 (indexed), in no event shall any portion of such dues be treated as derived by such organization from an unrelated trade or business by reason of any benefits or privileges to which members of such organization are entitled.73

7.3 Horticultural Groups

Horticulture is the cultivation of a garden or orchard and the science or art of growing fruits, vegetables, and flowers or ornamental plants. Under the IRS guidelines, horticulture is a division of agriculture and is subject to the same rules. However, no specific guidance or rules are provided exclusively for horticulture. To ponder the interesting dilemma, consider a group of rose growers that is conceivably eligible to qualify under both (c)(5) and (c)(6). A garden club might qualify under (c)(3), (c)(4), or (c)(7) depending on the focus of its activities.74 Certainly a garden club, the mission of which is to educate persons about horticulture, can qualify as a (c)(3) organization. A group of amateur gardeners not engaged in the business of growing plants for sale cannot qualify under (c)(5).

7.4 Disclosures of Nondeductibility

Dues attributable to political campaign participation and lobbying (other than on a local level) are not deductible for income tax purposes. In soliciting dues and other payments from their members, labor, agricultural, and horticultural organizations must make two different types of disclosures to their members in connection with soliciting payments, as follows:

  1. Nondeductibility as charitable contribution. A nonprofit organization exempt under (c)(5) that has gross revenue of $100,000 must print an express statement that payments to it, whether called dues, gifts, contributions, or something else, are not deductible as charitable contributions.
  2. Nondeductible dues attributable to lobbying. Members must be informed of that portion of their annual dues that is to be expended on lobbying and therefore is not tax deductible at all.75

An organization that fails to make the required disclosures is subject to penalties. Agricultural and horticultural organizations (but not labor unions) may qualify for an exclusion from the lobbying expense disclosure rule.76 If the organization is able to show that 90 percent or more of its members who each pay $7577 (indexed for inflation) or less do not benefit from the deduction of their annual dues or similar amounts due, no disclosure is required. Dues generally may not be deductible for an employee who claims the minimum standard deduction. The pre-2018 reduction for employee business expenses by 2 percent of adjusted gross income was eliminated for 2018 by the Tax Cuts and Jobs Act. A second type of safe harbor excludes an agricultural or horticultural organization that receives more than 90 percent of its annual dues from state or local government, §115 governmental instrumentalities, and §501(c) organizations not subject to this disclosure rule.

Notes

  1. 1 Discussed in §7.2(b).
  2. 2 See Chapter 20.
  3. 3 Exempt status, however, could be challenged if the private benefits are extensive.
  4. 4 Reg. §1.501(c)(5)-1(a).
  5. 5 IRM 7.25.5.2.
  6. 6 Id.
  7. 7 See §7.1(e).
  8. 8 Revised December 2010.
  9. 9 Rev. Rul. 76-31, 1976-1 C.B. 157.
  10. 10 Rev. Rul. 75-473, 1975-2 C.B. 213.
  11. 11 Rev. Rul. 67-7, 1967-1 C.B. 137.
  12. 12 Rev. Rul. 62-17, 1962-1 C.B. 87.
  13. 13 Rev. Rul. 62-191, 1962-2 C.B. 146; distinguished by Tech. Adv. Memos. 8015009 and 8146014 and Gen. Coun. Memo. 38981.
  14. 14 Rev. Rul. 59-6, 1959-1 C.B. 121.
  15. 15 Rev. Rul. 77-154, 1977-1 C.B. 148.
  16. 16 Rev. Rul. 68-534, 1968-2 C.B. 217.
  17. 17 Rev. Rul. 74-596, 1974-2 C.B. 167; Rev. Rul. 75-288, 1975-2 C.B. 212.
  18. 18 Portland Co-operative Labor Temple Association v. Commissioner, 39 B.T.A. 450 (1939), acq. 1939-1 C.B. 29. But see Stichting Pensioenfonds v. U.S., 950 F. Supp. 373 (D.D.C. 1996).
  19. 19 Priv. Ltr. Rul. 200649029.
  20. 20 Reg. §1.501(c)(5)-1(b).
  21. 21 Rev. Rul. 77-46, 1977-1 C.B. 147.
  22. 22 Rev. Rul. 69-386, 1969-2 C.B. 123.
  23. 23 Rev. Rul. 66-354, 1966-2 C.B. 207; distinguished by Gen. Coun. Memo. 37726.
  24. 24 Rev. Rul. 76-420, 1976-2 C.B. 153.
  25. 25 Rev. Rul. 67-7, 1967-1 C.B. 137.
  26. 26 Rev. Rul. 78-288, 1978-2 C.B. 179.
  27. 27 See §21.3.
  28. 28 IRM 7.25.5.5.
  29. 29 Marker v. Schultz, 485 F.2d 1003 (D.C. Cir. 1973).
  30. 30 See §23.6.
  31. 31 Supra note 9.Rev. Rul. 76-31, 1976-1 C.B. 157.
  32. 32 Rev. Rul. 77-154, 1977-1 C.B. 148.
  33. 33 Rev. Rul. 74-167, 1974-1 C.B. 134.
  34. 34 Rev. Rul. 78-288, 1978-2 C.B. 179.
  35. 35 Rev. Proc. 95-21, 1995-15 IRB 1, amplified and modified in part by Rev. Proc. 97-12, 1997-1 C.B. 631; see also Priv. Ltr. Rul. 9847001, in which the modest level of associate dues indicated a lack of desire to avoid limitations.
  36. 36 See §7.2.
  37. 37 American Postal Workers Union, AFL-CIO v. U.S., 925 F.2d 480 (D.C. Cir. 1991), rev'g 90-1 USTC 50,013 (D.D.C. 1989). See also Tech. Adv. Memo. 9742001.
  38. 38 National Association of Postal Supervisors v. U.S., 90-2 USTC 50,445 (Ct. Cl. 1990).
  39. 39 National League of Postmasters v. Commissioner, T.C. Memo. 1995-205.
  40. 40 Rev. Rul. 60-86, 1960-1 C.B. 198.
  41. 41 Priv. Ltr. Rul. 200939033.
  42. 42 Priv. Ltr. Rul. 201144030.
  43. 43 IRM 7.25.5.3.
  44. 44 Rev. Rul. 56-245, 1956-1 C.B. 204; there is no guidance on whether alligators raised for their skin qualify.
  45. 45 Rev. Rul. 55-230, 1955-1 C.B. 71. See also Gen. Coun. Memo. 39672 (group protecting a horse breed).
  46. 46 Rev. Rul. 73-520, 1973-2 C.B. 180; distinguished by Priv. Ltr. Rul. 8739066.
  47. 47 Forest City Livestock and Fair Co. v. Commissioner, B.T.A. Memo. 32,215 (1932).
  48. 48 Priv. Ltr. Rul. 200841038.
  49. 49 IRM 7.25.5.3.3.
  50. 50 East Tennessee Artificial Breeders Association v. U.S., 63-2 USTC 9748 (E.D. Tenn. 1963).
  51. 51 Indiana Crop Investment Association, Inc. v. Commissioner, 76 T.C. 394 (1981).
  52. 52 Campbell v. Big Spring Cowboy Reunion, 54-1 USTC 9232 (5th Cir. 1954). But see Louisiana Credit Union League v. U.S., 693 F.2d 525 (5th Cir. 1982).
  53. 53 Rev. Rul. 74-118, 1974-1 C.B. 134.
  54. 54 Rev. Rul. 76-399, 1976-2 C.B. 147.
  55. 55 IRM 7.25.5.1.1.
  56. 56 Rev. Rul. 74-195, 1974-1 C.B. 135; distinguished by Tech. Adv. Memo. 8115026.
  57. 57 Rev. Rul. 72-391, 1972-2 C.B. 249.
  58. 58 Rev. Rul. 66-105, 1966-1 C.B. 145.
  59. 59 Rev. Rul. 77-153, 1977-1 C.B. 147.
  60. 60 Rev. Rul. 67-252, 1967-2 C.B. 195.
  61. 61 Rev. Rul. 67-251, 1967-2 C.B. 196.
  62. 62 Rev. Rul. 76-399, 1976-2 C.B. 147.
  63. 63 Priv. Ltr. Rul. 201508011.
  64. 64 Tech. Adv. Memo. 9853001.
  65. 65 Rev. Rul. 70-372, 1970-2 C.B. 118; distinguished and clarified by Rev. Rul. 74-518, 1974-2 C.B. 166.
  66. 66 Rev. Rul. 74-518, 1974-2 C.B. 166; distinguished by Tech. Adv. Memo. 80380197. See also Priv. Ltr. Rul. 201716049.
  67. 67 Ohio Farm Bureau Federation, Inc. v. Commissioner, 106 T.C. 222 (1996).
  68. 68 Id. at 232.
  69. 69 Small Business Job Protection Act of 1996, §1115, adding new IRC §512(d).
  70. 70 See §7.1(e).
  71. 71 Rev. Proc. 2014-61, 2014-47, IRB 860.
  72. 72 Rev. Proc. 2013-35, 2013-47, IRB 537.
  73. 73 Rev. Proc. 2003-85, 2003-49 IRB 1184; updated by Rev. Proc. 2011-52, 2011-45 IRB.
  74. 74 Rev. Rul. 66-179, 1966-1 C.B. 139; also see §8.9 for comparison of (c)(5) and (c)(6) organizations.
  75. 75 IRC §6033(e); see §6.5 for a detailed explanation of these rules.
  76. 76 Rev. Proc. 98-19, 1998-1 C.B. 547.
  77. 77 Under Rev. Proc. 2019-44, effective for 2020, the membership dues amount below which nondeductible dues attributable to lobbying must be disclosed to members is $171. From 2011–2017, the rate was $105 and from 2008–2010, it was $101. Readers should look for updates in this inflation-adjusted amount in December.
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