Form 990 Schedule C: Mastering Complex Reporting of Political Campaign and Lobbying Activities

Avoiding Excise Taxes, Penalties, Fines, and Revocation of Tax-Exempt Status Due to Noncompliance

Recording of a 110-minute CPE webinar with Q&A

Conducted on Tuesday, April 4, 2017
Recorded event now available

This webinar will provide nonprofit advisers with a comprehensive guide to reporting on political campaign and lobbying activities on Schedule C of the Form 990 Exempt Organization Information Return. The panel will offer a practical part-by-part exploration of completing the schedule, focusing on identification and valuation of political and lobbying activities that must be separately reported. Because the majority of exempt organizations are classified under Section 501(c)(3), this webinar will focus on the requirements that pertain to charitable organizations.


Schedule C, Political Campaign and Lobbying Activities is required for exempt organizations that engage in political and lobbying activities. In practice, it can be challenging to discern how an organization should report to the IRS.

Depending on the filing organization’s exempt status, information reported on Form 990 Schedule C may include, among other things, a description of such activities, the amounts paid to Section 527 political organizations (if applicable), and a calculation of the organization’s lobbying limit and expenditures. Errors in tracking or reporting political and lobbying activities can result in excise taxes, penalties, fines and in some cases revocation of tax-exempt status.

Further complicating matters is that the IRS instructions do not always provide clear guidance on how to report certain items. The combination of limited guidance and the complexity of the reporting requirements present a particular challenge to nonprofit advisers.

Listen as our experienced panel provides detailed guidance on completing Form 990 Schedule C, with concrete examples of completed forms and schedules.


  1. Reporting political activities and lobbying on Form 990 Schedule C (three parts)
    1. Overview of Schedule C
    2. Political campaign activities overview
  2. Lobbying activities overview
    1. Substantial part test
    2. Expenditure test
  3. Form 990 Schedule C
    1. Form 990, Part IV, Lines 3-4: trigger questions
    2. Sch. C Part I: Political Campaign Activities
    3. Sch. C Part II: Lobbying Activities
    4. Part III: Proxy Tax (501(c)(4), 501(c)(5), and 501(c)(6) organizations only)


The panel will discuss these and other important topics:

  • How to identify which political and lobbying activities cross the line
  • Understanding the political campaign activity scenarios provided by the IRS Revenue Ruling 2007-41
  • Understanding differences between direct lobbying and grassroots lobbying
  • Learn by example, reporting of Form 990, Schedule C in three parts

Learning Objectives

After completing this course, you will be able to:

  • Identify which political and lobbying activities cross the line
  • Discern what an organization can and cannot do
  • Recognize differences between direct lobbying and grassroots lobbying


Deborah Kaminski, Director of Tax Exempt Organizations
DZH Phillips, San Francisco

Ms. Kaminski has spent 20 years in the nonprofit taxation and trust industry. She specializes in taxation of non-traditional investments, trust dissolutions, distribution calculations, excess-benefit transactions, and tax advisory services regarding nonprofit entities. She also helps clients identify and resolve compliance oversight.

Eric K. Gorovitz, Principal
Adler & Colvin, San Francisco

Mr. Gorovitz's practice spans the full range of nonprofit and tax-exempt legal issues, with emphasis on political advocacy and nonprofit corporate governance. He frequently presents on non-profit issues.

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Customer Reviews

Excellent seminar! It was efficient and the important topics were covered at just the right pace; no time was wasted covering information that the participants already knew.

Rhonda G. Williams, CPA

Barraclough & Associates

I liked the fact that there was more than one person presenting the material. It's nice to hear multiple perspectives.

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Cover & Rossiter

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Komisar Brady & Co.

The conference was technical, informative and presented at a good pace.

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Accounting Non-Profit Services Advisory Board

Amanda Adams

Tax Partner

Blazek & Vetterling

Bill Allen


Making Auditors Proficient

Steven J. Luber

Senior Manager


Michele A. W. McKinnon



Celia Roady

Tax Partner

Morgan Lewis

Daniel Romano

Partner-In-Charge, National Not-For-Profit Tax Practice

Grant Thornton

Chris Stanz

Principal, Non-Profit and Government Practice


Alan Strand


Strand and Associates

Brian Yacker

Managing Partner

YH Advisors | The Exempt Org Experts

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