Article on Citizens United and the Internal Revenue Code

John L. Buckley, a professor in the graduate tax program at GeorgetownUniversity Law Center, and Dallas Woodrum, a Georgetown law student serving as executivearticles editor for The Georgetown Law Journal, have published anarticle in Tax Notes discussing the use of tax-exempt organizations forpolitical purposes following Supreme Court decisions on campaign finance.  They propose legislative reforms, including(1) removing the benefit currently enjoyed by Code section 527 organizations ofthe income tax exclusion for dues and contributions from a single source thatexceed a specified amount; (2) eliminating the exclusion for capitalcontributions (and consideration in exchange for issued stock) received bycorporations when they have been utilized to expend such funds for politicalpurposes without disclosing the ultimate source of funds; (3) deeming politicalcontributions to result in dividend income to corporate insiders who authorize politicalcontributions in the absence of exante disclosure to, and authorization by, shareholders; and (4) providing moreobjective standards for determining whether issue advertisingconstitutes political campaign activity.  The electronic citation to the article is 2013TNT 68-5.

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