Nonprofits, campagn interventions and the Internet

The IRS has issued a new directive (PDF) that gives a couple of pages of not terribly helpful guidance on 501(c)(3)s links on their websites to affiliated and unaffiliated organizations. Nothing earth shattering in this doc other than what most nonprofit attorneys have been suggesting over the last few years: watch the context of your links. The one piece of good news is that it looks like the IRS isn't going to spend a lot of time looking at links to affiliated organizations (501(c)(4)s, etc.). I always appreciate guidance from the IRS, but restating the "facts and circumstances" analysis generally doesn't help too much. It's a double edged sword... less guidance may allow more leeway, but it also creates a lot of uncertainty as we head towards November.