{"version":1,"type":"rich","provider_name":"Libsyn","provider_url":"https:\/\/www.libsyn.com","height":90,"width":600,"title":"Are the 501(c)(4) Rules Changing?","description":"A recent Fifth Circuit holding in Memorial Hermann has caught the attention of lawyers in our space, with some wondering if the tax law rules on how 501(c)(4)s operate may change. But what did the court really say, and how should 501(c)(4) advocacy organizations react? On this special holiday edition of the pod, we are joined by Larry Gold of Trister Ross Schadler and Gold to understand what this case says and what it means for (c)(4)s in 2025 and beyond.  Attorneys for this episode  Tim Mooney  Susan Finkle Sourlis  Larry Gold, Trister Ross Schadler and Gold   Show notes  What is Memorial Hermann?  Very basics of the case  Basics of the holding  Where does this court\u2019s ruling apply?  501(c)(4) organizations must exclusively operate for the social welfare,  how is that interpreted to mean primarily, and the limit on items that do not as social welfare as secondary activity. We frequently talk about one of those secondary activities a lot \u2013 partisan political work. But this case focuses on another thing \u2013 can you explain why commercial activity does not promote social welfare?   The concern raised by some is the court\u2019s move to a smaller insubstantial standard for commercial activity may also apply to political activity, limiting the amount advocacy groups can engage in. How does the law treat commercial activity and political activity differently, and does that distinction matter here for other courts that may be addressing this?  Do (c)(4)s in the Fifth Circuit that engage in partisan political advocacy need to change what they\u2019re doing or how much they\u2019re doing? What about (c)(4)s outside of the Fifth Circuit?  There\u2019s another layer to all of this with (c)(4)s that have filed Form 1024s accepted by the IRS \u2013 can you explain what that is and why filing a 1024 now may be a good idea for some (c)(4)s that haven\u2019t yet?  What\u2019s happening next with this case?  What\u2019s your take on how various media outlets have presented this case \u2013 do you think they\u2019ve helped or muddied the waters?  On a scale of 1 to 10 where 1 is a yawn and 10 is metaphysical crisis, where are we now with Memorial Hermann for (c)(4)s?     Resources - Tim  The Rules of the Game      ","author_name":"Rules of the Game: The Bolder Advocacy Podcast","author_url":"https:\/\/afj.org\/podcast","html":"