Political Activity and Lobbying Guidelines for Catholic Organizations
The USCCB Office of General Counsel is providing these guidelines to (arch)dioceses, parishes, and other Catholic organizations ("Catholic Organizations") to assist them in distinguishing activities that are permitted during election campaigns from activities that are prohibited. The intended audience is Catholic organizations included in the USCCB group ruling that are exempt from federal income tax under section 501(a) of the Internal Revenue Code ("Code") and described in section 501(c)(3). State Catholic conferences that are included the USCCB's group ruling, or that are joint activities of two or more dioceses, are subject to the section 501(c)(3) rules; separately organized state Catholic conferences that are described in section 501(c)(4) are not. Therefore, the primary focus is on section 501(c)(3), which prohibits 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 seek from their own attorneys. Because interpretation of the political campaign intervention prohibition is inherently fact-specific, it frequently presents close questions that should be resolved with the advice of diocesan legal counsel. Such counsel should be sought prior to engaging in potentially problematic activities.