Christopher DeLacy is a Partner and Kenneth Parsons is
an Associate in Holland & Knight's
Washington D.C. office
On December 18, 2015, President Obama signed the Consolidated
Appropriations Act, 2016 (the "Act") into law. Among the
Act's many appropriations, extenders, and tax cuts are several
provisions that impact the shaky relationship between the IRS and
Section 501(c)(4) organizations. The provisions limit the extent to
which the IRS can issue guidance affecting Section 501(c)(4)
organizations, require such organizations to notify the IRS of
their formation, and make other clarifying changes. At least some
of these new provisions appear to be in response to the IRS's
alleged targeting of conservative organizations, which
came to light in May 2013 and the Act clarifies that IRS employees
who take official actions for political reasons may be
terminated.
