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Contributions to nonconnected PACs from partnerships

A partnership may make monetary or in-kind contributions aggregating up to $5,000 per calendar year to a nonconnected committee. In addition, a contribution from a partnership counts proportionately against each participating partner’s own limit with respect to the same committee.

Contributions made by individual partners

Each partner may make monetary or in-kind contributions aggregating up to $5,000 per calendar year to a nonconnected committee. Although contributions made by the partnership as a whole count proportionately against each partner’s $5,000 limit, contributions made by individual participating partners from their own funds do not count against the partnership’s limit.

Attribution among partners

Formula

A portion of the partnership contribution must be attributed to each contributing partner. If all partners within the organization are contributing, the partnership may attribute the contribution according to each partner’s share of the firm’s profits.

However, if the partnership attributes a contribution on another basis agreed to by the partners, or if it attributes contributions only to certain partners, the following rule must be observed:

  • The profits of only the partners to whom the contribution is attributed are reduced (or their losses increased) in the amount of the contribution attributed to them.

The portion attributed to each partner must not exceed the individual partner’s contribution limit when aggregated with other contributions from that person.

Notice to recipient committee

Because a contribution from a partnership is a joint contribution, the partnership must provide to the recipient committee, along with the contribution, a written notice listing the names of the contributing partners and the amount to be attributed to each. However, unlike other joint contributions, the signature of each contributing partner is not required.

Prohibited partnership contributions

Partnerships with corporate partners or members

Because contributions from corporations are prohibited, a partnership with corporate partners or members may not attribute any portion of a contribution to the corporate partners. A partnership composed solely of corporate partners or members may not make any contributions (except to Super PACs and the non-contribution accounts of Hybrid PACs).

Professional corporations

Although law firms, doctors’ practices and similar groups are often organized as partnerships, some of these groups may instead be organized as professional corporations. Unlike a partnership, a professional corporation is prohibited from making any contributions (except to Super PACs and the non-contribution accounts of Hybrid PACs).

Partnerships with foreign national members

Because contributions from foreign nationals are prohibited, a partnership may not attribute any portion of a contribution to a partner who is a foreign national.

Partnerships with federal government contracts

A partnership which is negotiating a contract with the federal government or which has not completed performance of such a contract is prohibited from making contributions. However, an individual partner in such a firm may make contributions from personal funds (rather than from funds drawn on the partnership’s accounts). Also, an individual who is in his or her own right, or as a sole proprietor, a federal government contractor may not make contributions using any funds (business or personal under his or her control (however the individual’s spouse is not prohibited from making a personal contribution).

Reporting partnership contributions

Included in total figure

Partnership contributions are included in the total figure reported for “Contributions from Individuals/Persons Other Than Political Committees” on the Detailed Summary Page of Form 3X.

Itemization

If a partnership contribution exceeds $200 or causes the partnership’s contributions to a candidate or committee to aggregate to over $200 during a calendar year, the committee must itemize the contribution on a Schedule A used for “Contributions from Individuals/Persons Other Than Political Committees” (Line 11a(i)).

Additionally, if an individual partner’s share of the contribution exceeds $200 when combined with other contributions received from that partner in the same calendar year, the committee must disclose, as a memo entry, itemized information on the partner (name, address, occupation, date contribution received, partner’s share of contribution and aggregate year-to-date total of contributions made by that partner).

In-kind contributions

A committee reports the value of an in-kind contribution from a partnership in the same way it reports a monetary contribution. In addition, as with all in-kind contributions, the committee must report the value of the in-kind contribution as an operating expenditure. Moreover, an in-kind contribution itemized on Schedule A must also be itemized on a Schedule B for operating expenditures. However, any information about a partner itemized as a memo entry on Schedule A does not have to be reported on Schedule B.

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