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10 WWW.UNWLA.ORG “НАШЕ ЖИТТЯ”, ВЕРЕСЕНЬ 2017 INTERNATIONAL ACTIVITIES and LOBBYING/ADVOCACY ____________________________________________________________________ Part II of presentation compiled by the UNWLA Parliamentarian, re- tired U.S. Administrative Law Judge Oksana Xenos, which was deliv- ered on May 28, 2017, by Vera Andrushkiw (President of Detroit Re- gional Council) at the UNWLA XXXI Convention in Tampa, Florida. The opinions expressed in this article are the author’s own and do not reflect the views of the Internal Revenue Service, the Social Security Ad- ministration, or the United States government. Questions often arise as to the international activities that our organiza- tion can perform, specifically relating to lobbying, advocacy, and making grants to foreign organizations or persons. Generally speaking, a US char- ity, like the UNWLA, can do anything in a foreign country that it can do in the US, as long as the activity is consistent with the charity’s exempt purposes. But our tax-exempt status can be revoked if we make grants to foreign organizations and cannot demonstrate that the grants were actually used for exempt purposes. In making grants to foreign entities, we must exercise reasonable care to ensure that our assets are used for charitable purposes. How do we make sure this happens? By maintaining procedures for properly vetting a foreign grantee, such as requiring a written application from the grantee and conducting background checks; By entering into an agreement with the foreign grantee that spells out the purpose of the grant; and By exercising oversight to ensure that the grant is used as intended. 1 Can donors designate their contributions to go to specific purposes ? Yes, donors may designate their con- tributions to go to a general purpose, such as earthquake relief. We may also accept non-binding recom- mendations or advice from donors. However, donors may not earmark funds for the use or benefit of any specific organization or individual. Can we distribute funds to foreign organizations that are not charities? Yes, we may distribute funds to foreign organizations that are not themselves charities. But, and this is an important caveat, we must be sure that the funds are used for specific projects that further our own exempt purposes. We must keep records to show that we control the distribution of the funds by implementing the following procedures: A procedure for an independent decision-making process on providing funds to foreign organi- zations; A pre-grant inquiry to be reasonably sure that the grant will be used for exempt purposes; A written agreement with the recipient regarding the use of the funds; and A report from the recipient that the funds were in fact used for approved exempt purposes. Are there transactions that are absolutely forbidden? Yes, the Treasury Department’s Office of Foreign Asset Control (OFAC) bans a broad range of programs in or with certain countries. OFAC also forbids transactions with specified individuals and organizations, which are listed on its website. 2 Violations can lead to civil fines and criminal penalties. What are the rules on international campaigning and lobbying? Just as within the US, a charity is pro- hibited from directly or indirectly participating in a political campaign of a candidate for a foreign public office, and it may not make a contribution to any such campaign. However, in a country ruled by a dicta- torship, a charity’s criticism of the regime in the course of advocating for democracy, the rule of law or human rights, would not ordinarily be regarded as intervention in a political campaign. Furthermore, we may not devote more than an insubstantial part of our activities to legislative lobbying. 3 However, there is no limit to the amount of advocacy that we can perform. The lines between advocacy and lobbying can easily become blurred, so it’s important to distinguish between the two. So let’s
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