Sample Comment #1: The proposed IRS regulation (IRS REG-134417-13) further involves the agency in regulating political speech, a function for which it lacks expertise or authority. Rather than address the cause of the IRS targeting scandal by removing the agency’s discretion in determining how much of a group’s activity is political, the proposed rulemaking simply prohibits a wide range of previously protected speech that will make it harder for social welfare organizations to pursue their missions, and restrict voters’ access to information about candidates. The proposed rule fails to create the clarity and fairness that is needed for true reform of the 501(c)(4) classification while unnecessarily weakening the institutions that voters rely on for information about candidates and Congressional representatives.
Sample Comment #2: The proposed IRS regulation (IRS REG-134417-13) threatens the ability of social welfare non-profit organizations to pursue their mission by restricting these groups’ political speech rights. It would leave these groups unable to effectively communicate with their members when bills are being considered by Congress that affect the group or its members and their goals, and unable to perform their historically vital role of connecting voters to candidates through events, voter guides, and get-out-the-vote drives. The proposed rulemaking should not proceed unless it is amended to preserve the political speech rights of 501(c)(4) organizations.
Sample Comment #3: The proposed IRS regulation (IRS REG-134417-13) will severely damage the ability of social welfare organizations to inform voters about candidates, leaving the public less informed and less able to effectively participate in civil society. Political speech rights curtailed by this rulemaking include such nonpartisan activities as hosting meet-the-candidate events, publishing voter guides, and get-out-the-vote drives. These activities serve an important function in connecting community members to their government and informing voters. The IRS should not proceed with a rulemaking that will restrict the ability of groups to communicate with voters about candidates and the issues that matter to them.
Sample Comment #4: The proposed IRS regulation (IRS REG-134417-13) will prevent citizen groups from engaging in important nonpartisan activities such as organizing voter registration drives, hosting meet-the-candidate events, and issuing nonpartisan voter guides. These activities improve civic engagement and do not serve to support or oppose any one candidate, and therefore should not be restricted. Groups should be allowed to engage in unlimited activity that educates the public about the electoral process, public policy, and public figures.
Sample Comment #5: The proposed IRS regulation (IRS REG-134417-13) will stifle a broad range of nonpartisan speech that will lead to a less informed electorate. The proposed regulation redefines “candidate-related political activity” to include any public communication that clearly identifies a candidate within 60 days of a general election or within 30 days of a primary election. As a result, groups affected by the proposed rule would be unable to inform or mobilize their members about pertinent pending legislation or regulatory matters during those windows, silencing important stakeholders in the policymaking process. The IRS must narrow the definition of candidate-related political activity to distinguish between nonpartisan activity and activity that supports or opposes a candidate.
Sample Comment #6: The proposed IRS regulation (IRS REG-134417-13) is an inappropriate attempt to regulate campaign finance through the Internal Revenue Service. The proposed regulation is not aimed at the agency’s legitimate purpose of raising revenue, but rather at silencing political speech from 501(c)(4) organizations. Unlike the Federal Election Commission, which has exclusive jurisdiction over campaign finance matters, the IRS lacks the authority and expertise necessary to effectively regulate political speech and campaign finance. As such, the proposed rulemaking should not proceed, and future efforts to change campaign finance regulation should go through Congress and the FEC.