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Churches and Charities After the Unsuccessful Settlement: Protecting Exemption Through Campaign Limits, Lobbying, and Affiliates

Midterm requests are already arriving, and the NRB consent judgment that might have changed the rules was never entered. Triage pulpit, livestream, email-list, forum, and ballot-measure requests, avoid §4955 taxes, make the 501(h) call, and sign c3/c4/PAC cost-sharing terms before resources move.

2026-11-12 12:00:00

Program Details

2026-11-12 12:00:00

2026-11-12 12:00:00

2h CLE Credits

2026-11-12 12:00:00

Program Details

2026-11-12 12:00:00

Program Details

2026-11-12 12:00:00

Over 1,000+ webinars

2026-11-12 12:00:00

Course Overview

The Endorsement Settlement Collapsed. Your Clients’ Midterm Questions Didn’t

2026-11-12 12:00:00

The National Religious Broadcasters consent judgment was never entered. Churches and charities face the November 3, 2026 midterms with the same prohibition and uncertain enforcement. The Rev. Rul. 2007-41 and 78-248 facts-and-circumstances and bias tests still decide every request.

Endorse a candidate from the pulpit, and exemption and §4955 excise taxes are at risk. Offer lists or space to one candidate on unequal terms, and a rental becomes campaign intervention. Blur the line with an affiliate, and its activity may be attributed to the 501(c)(3). Exceed the “insubstantial part” standard or the 501(h) limits, and lobbying becomes an exemption problem. Cross a federal LDA, state, or local threshold, and registration and reporting deadlines follow.

You walk out with work product, not doctrine: a ten-pattern decision matrix linking each request to its controlling facts, likely answer, and fix; an advice-letter framework for incomplete facts; a spending tracker coded to IRS, LDA, and state definitions; a c3/c4/PAC cost-sharing agreement; and registration checklists. These are judgment calls a generic summary cannot make for your client.

Format

CLE Credit

2h CLE Credits

Level

Intermediate

Length

2

Key topics that will be covered

01
Post-Settlement Enforcement Reality
Assess what the unentered judgment never reached, and how the §7611 gate and Form 13909 referrals shape exposure for churches and non-church 501(c)(3)s before November 3, 2026.
02
Ten Midterm Fact Patterns
Run pulpit, livestream, repost, list, title, facility, candidate-appearance, forum, and voter-guide requests through the Rev. Rul. 2007-41 and 78-248 tests using the facts that control each answer.
03
Ballot Measures and Lobbying
Decide when a ballot-measure effort is lobbying rather than campaign intervention, and make the 501(h) election call on a real budget while tracking direct, grassroots, and excluded communications.
04
§4955 Correction and Advice
Correct §4955 problems, address manager liability, and advise on incomplete facts with the decision matrix and an advice-letter framework.
05
Federal, State, and Local Registration
Confirm when Federal LDA registration and state and local lobbying registration and other triggers apply to nationally active clients, and track the thresholds and deadlines.
06
c3/c4/PAC Cost Sharing
Structure the c3/c4/PAC relationship so campaign intervention stays out of the c3, affiliates remain separate, and the cost-sharing agreement is signed before resources are shared.

Program schedule

clock 12:00 pm - 1:00 pm EST

Ten Midterm Fact Patterns for Church and Charity Campaign Activity After the Unsuccessful Settlement

This hour runs ten common election-season requests through the Rev. Rul. 2007-41 and 78-248 tests: a pulpit endorsement, livestream, repost, rented email list, leader’s use of title, candidate appearance, candidate forum, voter guide, facility rental, and ballot measure. For each, it identifies the key facts to collect—such as the speaker’s capacity, whether content stays posted, whether lists and space are offered to all candidates on equal terms at fair market value, how forum candidates are invited, and whether a ballot measure effort is lobbying rather than campaign intervention. It also considers what the unentered National Religious Broadcasters consent judgment might have changed and practical ways to avoid §4955 taxes: a different channel, a disclaimer where a leader speaks in an individual capacity, fair-market-value reimbursement, or an affiliate. Attendees take away a ten-pattern decision matrix linking each request to its controlling facts, likely answer, and fix, plus an advice-letter framework.

Patrick SternalPatrick Sternal
clock 1:10 pm - 2:10 pm EST

Building the c3/c4/PAC Structure With the 501(h) Election and State Lobbying Registration

This hour follows one advocacy client that wants to lobby and play a role in elections. Starting with the facts to collect—lobbying budget, staff time, communication types, list ownership, and jurisdictions—it builds the Form 5768 “h-election” call, a spending tracker coded to IRS, LDA, and state definitions, and a c3/c4/PAC cost-sharing agreement. It separates c3 lobbying (stay within limits and register when required), affiliate activity (maintain separation to avoid attribution), and campaign intervention (keep it out of the c3 and run it through the c4 or PAC). Attendees learn to update the tracker throughout the year, sign the cost-sharing agreement before sharing resources, and use the checklists to confirm registration and reporting deadlines.

Patrick SternalPatrick Sternal
Patrick Sternal

Patrick Sternal

Holtzman Vogel

Patrick Sternal

Patrick Sternal

Holtzman Vogel

Patrick Sternal is of counsel at Holtzman Vogel in Washington D.C. He has extensive experience in tax-exempt and nonprofit organization law, including as an Attorney Advisor in the IRS Office of Chief Counsel, where he worked on drafting regulations and other guidance and advising the IRS Exempt Organizations operating division, and as a Tax Law Specialist in the IRS Office of Tax Exempt and Government Entities, Rulings and Agreements, where he focused on exempt organization determinations and compliance. Before entering the IRS, he practiced law in Los Angeles, working primarily with exempt organization and nonprofit clients, including churches and religious organizations, charities, and social clubs. He is a graduate of Thomas Aquinas College (B.A. Liberal Arts), Ave Maria School of Law (J.D.), and Loyola Law School (LL.M. Taxation).

Education & Credentials

Patrick earned his LL.M. in Taxation with high distinction from Loyola Law School, his J.D. from Ave Maria School of Law, and his B.A. in Liberal Arts from Thomas Aquinas College. He is admitted to practice in California and the District of Columbia.

Recognition & Leadership

Patrick writes regularly on election-year rules for exempt organizations, including “Religious Organizations and Political Activity: A 2026 Election-Year Guide,” “Charitable Organizations in an Election Year: Frequently Asked Questions,” and “IRS Enters into Consent Decree Limiting Application of Johnson Amendment; New Position Allows Churches to Endorse Candidates in Certain Situations.” His other published work includes “IRS Form 990 Is Changing; Here’s Why Your Nonprofit Should Pay Attention,” “Back to Basics: Good Governance as Regulatory Prophylaxis,” and contributions to the firm’s In- Compliance political law updates.

Professional Involvement

Patrick is a member of the TEGE Exempt Organizations Council and the Catholic Bar Association. He has spoken alongside William M. Klimon at the Conservative Organizational Entrepreneur School.

Experience

At Holtzman Vogel, Patrick’s practice spans Non-Profit and Tax-Exempt Organizations, Faith-Based Organizations, Political Law, Corporate Governance, Government Ethics Compliance, and Higher Education Compliance. He counsels charities, social welfare organizations, and other exempt clients from formation and exemption applications through ongoing tax and governance questions, mergers, and dissolutions, and he drafts the contracts and agreements their transactions require.

Within government, Patrick served roughly ten years as a Tax Law Specialist in the IRS Office of Tax Exempt and Government Entities, Rulings and Agreements, working on exempt organization determinations and compliance, and later as an Attorney Advisor in the IRS Office of Chief Counsel, Exempt Organizations, where he drafted guidance and advised the operating division. Before joining the firm, he provided nonprofit tax and governance advice at a boutique law firm.
Patrick Sternal

Patrick Sternal

Holtzman Vogel

Patrick Sternal is of counsel at Holtzman Vogel in Washington D.C. He has extensive experience in tax-exempt and nonprofit organization law, including as an Attorney Advisor in the IRS Office of Chief Counsel, where he worked on drafting regulations and other guidance and advising the IRS Exempt Organizations operating division, and as a Tax Law Specialist in the IRS Office of Tax Exempt and Government Entities, Rulings and Agreements, where he focused on exempt organization determinations and compliance. Before entering the IRS, he practiced law in Los Angeles, working primarily with exempt organization and nonprofit clients, including churches and religious organizations, charities, and social clubs. He is a graduate of Thomas Aquinas College (B.A. Liberal Arts), Ave Maria School of Law (J.D.), and Loyola Law School (LL.M. Taxation).

Education & Credentials

Patrick earned his LL.M. in Taxation with high distinction from Loyola Law School, his J.D. from Ave Maria School of Law, and his B.A. in Liberal Arts from Thomas Aquinas College. He is admitted to practice in California and the District of Columbia.

Recognition & Leadership

Patrick writes regularly on election-year rules for exempt organizations, including “Religious Organizations and Political Activity: A 2026 Election-Year Guide,” “Charitable Organizations in an Election Year: Frequently Asked Questions,” and “IRS Enters into Consent Decree Limiting Application of Johnson Amendment; New Position Allows Churches to Endorse Candidates in Certain Situations.” His other published work includes “IRS Form 990 Is Changing; Here’s Why Your Nonprofit Should Pay Attention,” “Back to Basics: Good Governance as Regulatory Prophylaxis,” and contributions to the firm’s In- Compliance political law updates.

Professional Involvement

Patrick is a member of the TEGE Exempt Organizations Council and the Catholic Bar Association. He has spoken alongside William M. Klimon at the Conservative Organizational Entrepreneur School.

Experience

At Holtzman Vogel, Patrick’s practice spans Non-Profit and Tax-Exempt Organizations, Faith-Based Organizations, Political Law, Corporate Governance, Government Ethics Compliance, and Higher Education Compliance. He counsels charities, social welfare organizations, and other exempt clients from formation and exemption applications through ongoing tax and governance questions, mergers, and dissolutions, and he drafts the contracts and agreements their transactions require.

Within government, Patrick served roughly ten years as a Tax Law Specialist in the IRS Office of Tax Exempt and Government Entities, Rulings and Agreements, working on exempt organization determinations and compliance, and later as an Attorney Advisor in the IRS Office of Chief Counsel, Exempt Organizations, where he drafted guidance and advised the operating division. Before joining the firm, he provided nonprofit tax and governance advice at a boutique law firm.

Credits by state

AK2.0
AL2.0
AR2.0
AZ2.0
CA2.0
CO2.0
CT2.0
DC2.0
DE2.0
FL2.0
GA2.0
HI2.0
IA2.0
ID2.0
IL2.0
IN2.0
KS2.0
KY2.0
LA2.0
MA2.0
MD2.0
ME2.0
MI2.0
MN2.0
MO2.4
MS2.0
MT2.0
NC2.0
ND2.0
NE2.0
NH120.0
NJ2.0
NM2.0
NV2.0
NY2.0
OH2.0
OK2.5
OR2.0
PA2.0
RI2.5
SC2.0
SD2.0
TN2.0
TX2.0
UT2.0
VA2.0
VT2.0
WA2.0
WI2.0
WV2.4
WY2.0

1000+

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24/7

Access to live webinars & recordings

70,000+

Trusted by Legal Professionals

1000+

Live stream programs

24/7

Access to live webinars & recordings

70,000+

Trusted by Legal Professionals

1000+

Live stream programs

24/7

Access to live webinars & recordings

10,000+

Trusted by Legal Professionals

1000+

Live stream programs

24/7

Access to live webinars & recordings

70,000+

Trusted by Legal Professionals

MCLE Credits

Alabama
Pending
Alaska
Approved
Arizona
Approved
Arkansas
Approved
California
Approved
Colorado
Pending
Connecticut
Approved
Delaware
Pending
District of Columbia
No Required
Florida
Approved
Georgia
Pending
Hawaii
Approved
Idaho
Pending
Illinois
Pending
Indiana
Pending
Iowa
Pending
Kansas
Pending
Kentucky
Pending
Louisiana
Pending
Maine
Pending
Maryland
No Required
Massachusetts
No Required
Michigan
No Required
Minnesota
Pending
Mississippi
Pending
Missouri
Approved
Montana
Pending
Nebraska
Pending
Nevada
Pending
New Hampshire
Approved
New Jersey
Approved
New Mexico
Approved
New York
Approved
North Carolina
Pending
North Dakota
Approved
Ohio
Pending
Oklahoma
Pending
Oregon
Pending
Pennsylvania
Approved
Rhode Island
Pending
South Carolina
Pending
South Dakota
No Required
Tennessee
Pending
Texas
Approved
Utah
Pending
Vermont
Approved
Virginia
Not Eligible
Washington
Approved
West Virginia
Pending
Wisconsin
Pending
Wyoming
Pending

Alabama

Requirements

The Alabama State Bar MCLE Commission requires attorneys to complete 12 credits, including 1 ethics, by December 31 of each year. All credits must be reported by February 15 of the following year. A maximum of 12 credits, including 1 ethics credit, may be carried over for 1 year only.  

Formats

  • Attorneys can earn unlimited “live” credit through live seminars, live webcasts, and co-sponsored locations with MyLAWCLE-Alabama approved programs
  • Attorneys are limited to 6 credits per compliance period of “online” programs through MyLAwCLE On-Demand programs