501(c)(3) vs. 501(c)(4) Gift-Routing & Disclosure Guide
An operational decision guide for organizations running an affiliated (c)(3)/(c)(4) structure — common in conservation and climate advocacy — to route each gift correctly and keep the charitable/advocacy wall clean.
Draft: pending review
This starter document is signed off by Nonprofit counsel (affiliated c3/c4, lobbying & election law) + CPA before it ships. The guardrails below define that review.
What’s inside
- Decision tree: which entity receives a gift based on donor intent and use (program/education vs. lobbying/political)
- Point-of-solicitation disclosure templates for (c)(4) and split asks
- Cost-sharing/shared-staff allocation checklist (arm's-length, documented)
- Receipting differences: deductible (c)(3) vs. explicit 'not deductible' (c)(4) statement
Legal & ethical guardrails
The sector-specific compliance points this document must honor.
- 501(c)(4) contributions are not tax-deductible as charitable gifts — solicitations and receipts must say so explicitly
- (c)(3) resources transferred to the (c)(4) must be at fair market value with documentation to avoid impermissible private benefit
- (c)(3) lobbying is capped (insubstantial-part or 501(h)) and no partisan activity is permitted; route campaign-adjacent asks accordingly
- Donor-intent integrity: a donor intending a deductible gift must land in the (c)(3)
Held for professional review.
The native DOCX and full working text ship only after sign-off by Nonprofit counsel (affiliated c3/c4, lobbying & election law) + CPA on this exact version. The summary and review requirements remain visible in the meantime.
Not legal advice. Not legal, tax, or accounting advice. The Fundraising Co. provides educational fundraising materials and is not a law firm; nothing here creates an attorney–client relationship or substitutes for advice from professionals licensed in your jurisdiction. Laws and IRS rules vary by state and change over time. Review every document with qualified counsel before use.