| Policy Name: | Political Expression and Activity |
|---|---|
| Scope: | All Staff and Associates |
| Revision Date: | June 20, 2022 |
| Last Review Date: | June 15, 2023 |
Introduction
We understand that faith in Christ often has an outworking in personal social or political engagement. Naturally, Reliant employees and associates are free and supported to engage in political expression or activities as individual citizens in accordance with their consciences and within the broad bounds of Reliant’s Code of Conduct. However, as 501(c)(3) tax-exempt organizations, churches and non-profit organizations may not “participate in, or intervene in (including the publishing or distributing of statements), any political campaign on behalf of (or in opposition to) any candidate for public office” (see the IRS Guidance for Charities, Churches and Politics). Thus, for the purposes of this policy, partisan political expression and activity refer to actions or statements that support or oppose a political candidate, campaign, or party, while non-partisan political expression and activity refer to advocacy or opposition to particular issues that are not directly associated with a political candidate, campaign, or party. An example of a nonpartisan activity may be a march for racial justice or the right to life; an example of a partisan activity (and therefore prohibited activity on work time) is a rally for a Republican or Democratic political party or candidate.
Guidance on Political Expression and Activity
- All participation in political expression or activism (in person and on social media) in any context MUST be done in alignment with Reliant’s Code of Conduct.
- Political expression or activities that support or oppose a political candidate, campaign, or party (partisan activities) should not be conducted concurrently with Reliant job responsibilities (i.e., they should not be conducted when a Reliant missionary or Central employee would be reasonably perceived as being “on the job” with Reliant).
- Employees or associates should not state that they represent Reliant or the views of Reliant during any kind of political expression or activism (including on social media).
- Employees or associates should not state that they represent their partner church or ministry in any kind of political expression or activism (including on social media) UNLESS they receive express permission from their church or ministry leaders AND the expression or activity is nonpartisan and does not violate the IRS regulations for churches and tax-exempt organizations.
- Reliant and the partner church or ministry leadership should respect the personal political beliefs or expressions of Reliant employees (made within Reliant’s Code of Conduct or other policies) and of others with whom Reliant employees interact.
2 Comments
Julie Thomas
Board approved on 6/7/2022
Julie Thomas
From Church Law & Tax, April 2022
ACTIVITY
IMPACT ON TAX- EXEMPT STATUS
BASIS
A church makes contributions to a candidate’s campaign fund
Prohibited
IRS Publication 1828
A church makes public statements of position (verbal and written) in favor of or in opposition to candidates for office through official church publications, at official church functions, or both
Prohibited
IRS Publication 1828
A church’s pastor delivers a sermon series addressing what the Bible says about abortion, criminal justice reform, sexual orientation and gender identity, and other topics with social and spiritual implications
Permitted
First Amendment of the US Constitution
A church provides a nonpartisan forum for all candidates to address the church
Permitted
IRS Publication 1828
A church invites all candidates for a political office to address the congregation and informs the congregation before each candidate’s speech that the views expressed are those of the candidate and not the church, and that the church does not endorse any candidate
Permitted
Revenue Ruling 74-574; IRS Publication 1828
A church invites only one candidate in a political campaign to address the congregation
Prohibited
Revenue Ruling 2007-41; IRS Publication 1828
A church provides an opportunity for a candidate to speak in a noncandidate capacity (for example, as a member of the church, public figure, or expert in a nonpolitical field) without providing equal access to all political candidates for the same office. The church ensures that the candidate speaks in a noncandidate capacity; no reference is made to the person’s candidacy; the church mentions the capacity in which the candidate is appearing (without mentioning the person’s political candidacy); and no campaign activity occurs.
Permitted
IRS Publication 1828
A church distributes a compilation of voting records of all members of US Congress on major legislative issues involving a wide range of subjects; the publication contains no editorial opinion, and its text, design elements, and structure do not imply approval or disapproval of any members or their voting records
Permitted
Revenue Ruling 78-248; IRS Publication 1828
A church distributes a voter guide containing questions answered by all candidates. The questions cover a wide range of topics, but the wording of the questions demonstrates bias on certain issues.
Prohibited
Revenue Ruling 78-248; IRS Publication 1828
A church endorses a candidate (by any variety of ways, including verbal or written statements, references to the candidate’s political party, references to the candidate’s distinctive platform or biography, and/or showing the candidate’s picture)
Prohibited
Int. Rev. News Release IR-96-23; IRS Publication 1828
Church employees carry on campaign activities for a candidate within the context of their church employment
Prohibited
FSA 1993-0921-1; IRS Publication 1828
A church fails to “disavow” the campaign activities of persons under “apparent authorization” from the church by repudiating those acts “in a timely manner equal to the original actions” and taking steps “to ensure that such unauthorized actions do not recur”
Prohibited
FSA 1993-0921-1
A church engages in fundraising on behalf of a candidate
Prohibited
Int. Rev. News Release IR-96-23; IRS Publication 1828
A church conducts a neutral voter registration drive
Permitted
11 C.F.R. § 111.4(c)(4); IRS Publication 1828
A church buys and places newspaper ads urging voters to vote for or against a candidate
Prohibited
Branch Ministries, Inc. v. Commissioner, 99-1 USTC ¶50,410 (D.D.C. 1999), aff’d, Branch Ministries v. Rossotti, 2000 USTC ¶50,459 (D.C. Cir. 2000)
A church website contains information either supporting or opposing candidates for public office
Prohibited
IRS Publication 1828
A church website contains links to candidate-related materials, and does not include any text, design elements, or structure indicating support of or opposition to any of the candidates
Permitted
Revenue Ruling 2007-41; IRS Publication 1828
A church website links to third-party websites containing materials supporting or opposing candidates
Prohibited
IRS Publication 1828
A minister who is known well in the community attends a press conference at a political candidate’s campaign headquarters and states that the candidate should be reelected. The minister does not say he is speaking on behalf of his church. His endorsement is reported on the front page of the local newspaper, and he is identified in the article as the minister of his church.
Permitted
Revenue Ruling 2007-41; IRS Publication 1828
A church maintains a website that includes biographies of its ministers, times of services, details of community outreach programs, and activities of members of its congregation. A member of the congregation is running for a seat on the town council. Shortly before the election, the church posts the following message on its website: “Lend your support to your fellow parishioner in Tuesday’s election for town council.”
Prohibited
Revenue Ruling 2007-41; IRS Publication 1828
A church urges its members to contact members of the state legislature and urge them to reject a proposed bill legalizing marijuana
Prohibited
IRS Publication 1828
A church provides its members with educational materials about the legalization of marijuana and hosts an educational meeting on the topic
Permitted
IRS Publication 1828
A church gives a pro-life advocacy group permission to place pamphlets on vehicles in the church’s parking lot during Sunday worship services. The pamphlets urge congregants to support a “pro-life” slate in the upcoming election.
Unclear based on IRS regulations and current law—but likely prohibited
A church owns space suitable for events and makes it available for rent to the public on a first come, first served basis. A candidate pays the standard fee to host a campaign dinner.
Permitted
IRS Publication 1828
A church sets up a booth at the state fair where citizens can register to vote. The booth only contains the church’s name, the date of the next statewide election, and notice of the opportunity to register. No reference to any candidate or political party is made in any materials or in any statements given by volunteers.
Permitted
IRS Publication 1828
A church maintains a list containing contact information for its members and has never rented it to a third party. The church allows one candidate to rent the list to send campaign information, but declines similar requests from other candidates.
Prohibited
IRS Publication 1828
A church sets up a telephone bank to conduct a “get-out-the-vote” effort and contacts registered voters in its district. Church volunteers are instructed to ask the registered voters about their positions on certain moral issues, and if the voter’s positions align with a specific candidate running for office in the district, to then remind them about the upcoming election, the importance of voting, and the availability of church-sponsored transportation to the polls.
Prohibited
IRS Publication 1828
source: https://www.churchlawandtax.com/web/2022/april/how-various-political-activities-might-affect-tax-exempt-st.html