Who Can Give to Whom, and When: Questions and Answers

This lesson is the lookup table for the rest of the course. Each answer is short and points to the lesson that explains it. Start with the matrix if you know who is giving and who is receiving. Start with the calendar if your question is "when." The Q&A below them is grouped by relationship, written the way people actually ask. For schools, churches and religious organizations in more detail, see lesson 12; this page gives only the short answers.

The relationship matrix

Read across a row: that giver, to each receiver or kind of spending. "No limit" means no Idaho cap; reporting duties still apply. Candidate limits are per election, primary and general counted separately (Idaho Code 67-6610A).

Giver	To a candidate committee	To an Idaho PAC	To a party committee	To a ballot-measure committee	Independent spending on a candidate	Spending on an initiative
Individual	$1,000 legislative, judicial, local; $5,000 statewide (67-6610A(1))	No limit	No limit	No limit	No limit; statement over $100 (67-6611)	No limit; 67-6611 if express advocacy over $100
Candidate, own money	Own campaign: no limit. Another candidate: shares one limit with own committee (SOS tip sheet)	No Idaho limit, but the SOS tip sheet says give personally or from the campaign, not both; a candidate's own PAC may not fund the candidate's race	No limit	No limit	No limit; 67-6611	No limit
Candidate committee	Within that candidate's limit (67-6610C(1)(e))	As "any other lawful purpose," never personal use (67-6610C(1)(f)); the SOS tip sheet treats it as allowed but shared with the candidate's own gifts	Unlimited transfers (67-6610C(1)(d))	Lawful purpose (67-6610C(1)(f))	Reported as campaign spending; 67-6611 over $100	Lawful purpose; report it
Idaho PAC	Same limits as an individual; coordinated spending counts as in-kind	No limit	No limit	No limit	No limit; 67-6611, 48-hour rule	No limit
Independent expenditure committee	Not a separate Idaho category; a PAC that gives is held to the limits	No limit	No limit	No limit	Its purpose; 67-6611	No limit
Party committee	County or state: $2,000 legislative. Statewide: state central $10,000, county $5,000. Local $1,000. 2026 general coordinated spending not capped (Guidance 2026-3)	No limit	No Idaho limit	No limit	No limit; 67-6611	No limit
Ballot-measure committee	Within limits, but the committee then backs candidates and is no longer measure-only	No limit	No limit	No limit	Same caveat	Its purpose
501(c)(3) charity	Barred (IRS FAQ)	Barred if the PAC backs or fights candidates	Barred	Allowed, counted as lobbying (IRS FAQ)	Barred	Allowed as lobbying; 67-6606 over $1,000
Church	Barred	Barred	Barred	Allowed as lobbying; substantial part test only	Barred	Allowed; 67-6606 with the narrow general-donor relief in Guidance 2026-6
501(c)(4)	Within limits; not its primary activity; 527(f) tax may apply	Allowed; 527(f) for candidate PACs	Allowed; 527(f)	Allowed	Allowed if not primary activity	Allowed. All of it counts toward the 67-6606 $1,000
501(c)(6)	Same as (c)(4), plus dues notice or proxy tax	Allowed	Allowed	Allowed	Allowed if not primary activity	Allowed; 67-6606
Corporation or LLC	Within limits; related entities share one limit (67-6610A(6)); national banks barred	No limit	No limit	No limit	No limit; 67-6611	No limit
Union	Within limits, through a separate political fund where Title 44, Chapter 26 applies; committees it controls share its limit	Through that fund	Through that fund	Through that fund	Through that fund	Through that fund
Federal PAC	Within limits from its federal account; no Idaho registration if current with the FEC and not earmarked (Guidance 2026-4)	Same conditions	Same conditions	Same conditions	67-6611 statement with its FEC ID	67-6611 statement for its own ads; raising money for the measure or spending past $1,000 on it means Idaho registration (2026-4)
Super PAC	Never to federal candidates. A federal PAC giving to state candidates answers to federal and state law (FEC), so Idaho limits and 2026-4 conditions apply	No Idaho limit; 2026-4 conditions	No Idaho limit	No Idaho limit	67-6611 with FEC ID; coordinating or raising for Idaho means Idaho registration	Same
Foreign national	Barred (67-6610D; 52 U.S.C. 30121)	Barred	Barred	Barred (67-6610D names measures)	Barred	Barred

When: the calendar

Stage	What applies	Rule
Before a treasurer is appointed	No contribution may be received and no expenditure made until a political treasurer is appointed and certified. Testing the waters with personal funds is not candidacy. Local and judicial candidates and local committees do not file until $500 (general-purpose local committees $1,000).	67-6603(c)(1); 67-6608
Primary period (May 19 in 2026)	Every gift is designated primary or general. Gifts before the primary go to the primary limit. General money may be taken early.	67-6610A; SOS Disclosure Manual
General period (Nov. 3 in 2026)	A fresh limit for each giver. A candidate who loses the primary returns general-election gifts. Recall and special elections count as general elections.	67-6610A(4)
48-hour windows	Contributions of $1,000 or more: any time of year. Independent expenditures of $1,000 or more: after the 16th day before an election, until 48 hours before it. Electioneering costs of $1,000 or more: any time in the window. Signature gatherer payments of $1,000 or more: the 14 days before the election.	67-6607(3); 67-6611(4); 67-6628; 67-6612
Electioneering windows	30 days before a primary, 60 days before a general. In 2026: April 19 to May 19, and September 4 to November 3. Independent expenditure statements due 7 days before each election (Oct. 27) and 30 days after (Dec. 3).	67-6602(6); 67-6611(2)
Voting days	No electioneering, handbills, petition signature gathering or vote soliciting inside a polling place or within 250 feet of its primary entrance, on any day ballots are cast in person.	18-2318
After the election	Debt may be paid with new gifts for that election, within its limits. Surplus goes to the uses in 67-6610C(1). Reports continue until there is no balance and no debt.	67-6610B; 67-6610C; 67-6607(5)
Initiative circulation	File with 20 signers; ballot title (it becomes a measure, and gatherer pay becomes reportable); fiscal impact statement; circulate up to 18 months or until April 30 of the election year; signatures to county clerks by May 1; clerks verify by the end of June; file with the Secretary of State at least four months before the election.	34-1802; 67-6602(11); 67-6612

Individuals and candidates

Can I give my candidate friend $5,000?

Only if your friend is running statewide, and then only $5,000 for the primary and $5,000 for the general. For a legislative, judicial, county, city or school race the cap is $1,000 per election under 67-6610A(1), so $2,000 across both. For a congressional race the federal limit is $3,500 per election. Lesson 2 has the full table.

Can I pay for my friend's yard signs instead of writing a check?

Yes, but it is still a gift. Goods and services count at fair market value against your limit under 67-6610A(5), and the campaign reports them as an in-kind contribution. If you buy signs on your own without talking to the campaign and they expressly advocate, you have made an independent expenditure instead (lesson 5).

Is there a limit on how much of my own money I can put into my campaign?

No. 67-6610A(1) excludes a candidate's own contributions and loans to the campaign account. A loan over $1,000 has to go into the campaign checking account, and any gift or loan of $1,000 or more needs a 48-hour notice (lesson 3).

Candidates and PACs

Can a PAC give to my campaign?

Yes, at the same limit as an individual: $1,000 per election for most offices, $5,000 statewide. A PAC that pays for an ad after you approve it has also given you something, and that in-kind value counts against the same limit (lesson 4).

Can I start a PAC to support other candidates?

Yes. It registers like any political committee and may raise unlimited amounts. The Secretary of State's tip sheet says a candidate's PAC may spend only on other candidates, and 67-6610A counts gifts to "political committees organized on the candidate's behalf" against the candidate's own limit, so it cannot be a side door into your race (lesson 4).

Can my campaign give money to a PAC?

Yes, though the statute does not list it by name. 67-6610C(1) allows campaign spending, officeholder expenses, charities, unlimited party transfers, other candidates within the limits and "any other lawful purpose" that is not personal use. A gift to a PAC falls in that last bucket. The Secretary of State's campaign tip sheet treats gifts from a candidate or the campaign "to other campaigns or PACs" as allowed under a single limit: the candidate may give personally or from the campaign account, but not both. For a gift to a ballot-measure committee, which the tip sheet does not mention, put the question to the elections division in writing before the check goes out.

Can my campaign give to another candidate?

Yes, within that candidate's limit (67-6610C(1)(e)). The Secretary of State's tip sheet says your personal gift and your campaign's gift to the same candidate share one limit.

PACs and PACs

Can a PAC give to another PAC?

Yes, with no Idaho limit. The giving PAC reports an expenditure and the receiving PAC reports a contribution with the giver's name and address. Federal PACs face a $5,000 a year limit on gifts to other federal PACs, which does not apply to Idaho committees (lesson 2).

Can a PAC pass a donor's money to a candidate to get around the donor's limit?

No. Idaho Code 67-6614 bars giving through another person to hide the source, and a committee funded entirely by one person who controls it counts as that person under 67-6610A(6)(a). If the donor told the PAC where the money should go, treat it as the donor's gift.

If our PAC only spends on its own ads, is there any cap on what it raises?

None in Idaho; no Idaho PAC has a receipt limit. The constraint is disclosure: every donor over $50 a year goes on the public report, and each gift of $1,000 or more gets a 48-hour notice.

Nonprofits and campaigns

Can my 501(c)(3) pay for a candidate forum?

Yes, if the forum is neutral. Rev. Rul. 2007-41 asks whether an independent nonpartisan panel prepares the questions, whether the topics cover a broad range of issues, whether each candidate gets an equal chance to answer, whether candidates are asked to agree or disagree with the group's positions, and whether the moderator signals approval or disapproval. Invite every qualified candidate; equal opportunity is the test. A forum staged for one candidate is campaign intervention, and its cost becomes an in-kind gift the charity was barred from making (lesson 8).

Can our 501(c)(3) give to an Idaho PAC?

Not if the PAC supports or opposes candidates; the IRS FAQ says a 501(c)(3) "may not make a contribution" to a candidate committee, party committee or PAC. It may give to a committee formed only for a ballot measure, counted in its lobbying totals. Read the committee's Sunshine reports first, because one candidate gift makes it a mixed committee. Lesson 8 walks through both answers.

Can a 501(c)(4) give to a candidate?

For an Idaho race, yes, within the same limits as any corporation or group. The IRS lets a (c)(4) do some political work if it is not the primary activity, and section 527(f) may tax the spending. For a federal race, no: federal law bars corporations, nonprofit corporations included, from giving to federal candidates.

Our board chair wants to endorse a candidate. Can she?

As herself, yes, on her own time and outside the organization's newsletter, website, events and pulpit. If the group is a 501(c)(3), the endorsement cannot appear in any official publication or function (lesson 8). A (c)(4) or (c)(6) may endorse as a group, within its primary-purpose limit.

Nonprofits and initiatives

Can a church give to an initiative campaign?

Yes. Federal tax law treats an initiative as legislation, so a church's gift counts as lobbying, and churches must use the substantial part test because they cannot elect 501(h). In Idaho, spending more than $1,000 in a year triggers a 67-6606 statement; Guidance 2026-6 lets a church leave general donors off in narrow conditions, never for money collected specifically for the campaign. Lesson 12 has the detail.

Can our charity spend its own money campaigning for a county levy?

Yes, as lobbying within its limit. Under the 501(h) formula, a message urging voters to pass or defeat a measure is direct lobbying. Past $100 of express advocacy for the levy, the charity files 67-6611 statements; past $1,000 for the year, a 67-6606 statement (lesson 8).

Will spending on a measure expose our general donors?

It can. The 67-6606 statement names every person who paid the group more than $500 in either of the two prior calendar years, or who paid or agreed to pay more than $500 in the current year, whatever the money was for. Guidance 2026-5 recommends a separate PAC so only its own donors are named.

Businesses, unions and LLCs

Can an LLC I own give separately from me?

Yes. The Disclosure Manual says a person and that person's own business may each give up to the limit. A second or third company with the same majority owners does not add a limit: 67-6610A(6)(c) counts them as one. In 2026 two legislative candidates returned money after three same-owner LLCs gave $1,000 each (lesson 2).

Can my company give to a state candidate?

Yes, up to the same limit as a person; the manual says the Sunshine Law "in no way restricts" corporations within the limits. National banks and federally chartered corporations are the exception: 52 U.S.C. 30118 bars them in every election.

Can a union give?

Yes, within the limits, with conditions. Where Idaho Code Title 44, Chapter 26 applies, mainly public employee associations, political money must come from a separate fund of voluntary gifts registered as an Idaho political committee, and 44-2004(2) bars payroll deduction for politics. Any committee a union finances or controls shares the union's limit (67-6610A(6)(b)).

Can a business give unlimited money to a ballot-measure committee?

Yes. Idaho caps no gift to a measure committee, and the U.S. Supreme Court struck down limits on contributions to measure committees in Citizens Against Rent Control v. Berkeley (1981). The committee reports the business by name (lesson 7).

Parties

How much can our county party give a legislative candidate?

$2,000 for the primary and $2,000 for the general, the same as the state central committee. The higher statewide limit, $10,000 per election, belongs to the state central committee alone (67-6610A(2)). A county committee giving to a statewide candidate falls under the ordinary $5,000 limit in 67-6610A(1)(b), and for local candidates the party uses the ordinary $1,000 limit (lesson 2).

Can a party now spend without limit on its nominee?

For the 2026 general election, coordinated spending, yes. Guidance 2026-3 says the office will not apply 67-6610A to a state or county central committee's spending coordinated with its nominee, reported as a regular expenditure. Money handed to the candidate is still capped, and PACs, individuals and businesses that coordinate get no relief.

Can a candidate send leftover money to the party?

Yes, in any amount. 67-6610C(1)(d) allows transfers "without limitation" to a national, state or local party committee.

Independent spending and coordination

Can a candidate coordinate with a Super PAC?

No, not without destroying what makes it a Super PAC. The FEC says a communication made in cooperation with or at the suggestion of a candidate counts against contribution limits, and a Super PAC exists to spend unlimited money independently. In an Idaho race, coordinated spending is an in-kind gift under 67-6610A and a federal committee that coordinates must register in Idaho (Guidance 2026-4).

I want to buy newspaper ads for a candidate myself. What do I file?

If you spend more than $100 for one candidate without talking to the campaign, file 67-6611 statements 7 days before and 30 days after the election, plus a 48-hour statement for $1,000 or more in the final 16 days. Identify yourself on the ad as the person responsible, usually with a "Paid for by" line (67-6614A). Use the nonregistered filer page on the Sunshine portal (lesson 10).

The candidate saw my ad before it ran and said "looks good." Does that matter?

Yes. Prior consent ends independence under 67-6602(9), so the ad's cost is an in-kind contribution the candidate reports, and it counts against your limit. Over the limit, the excess must be refunded or never spent.

Does a postcard that never says "vote for" need a report?

Inside the window, often yes. A piece that unambiguously refers to a candidate within 30 days of a primary or 60 days of a general and reaches that office's voters is an electioneering communication, and spending over $100 means a 67-6628 statement listing everyone who gave the spender $50 or more (lesson 5).

Initiatives and ballot measures, from petitions to election day

When does an initiative committee have to start reporting?

The proposal becomes a "measure" under 67-6602(11) when it receives its ballot title, and a committee designated to support or oppose it reports from then on. Payments to signature gatherers become reportable under 67-6612 from the same date. Since signatures may be gathered only after the ballot title and fiscal impact statement arrive, reporting starts before the first signature. Register when the committee forms (lesson 7).

Can we pay signature gatherers, and what do we report?

Yes. Anyone paying $100 or more reports by the 20th of the following month, naming each gatherer paid more than $50, under 67-6612. Paid circulators must be Idaho residents, wear the "paid petition circulator" badge and disclose who pays them under 34-1807.

Can a school district spend money on its own bond campaign?

Only on neutral facts. The Public Integrity in Elections Act, 74-604, bars public funds and resources for advocacy; 74-605 allows an objective statement with the cost figures 34-913 requires. Lessons 7 and 12 cover schools.

Can I gather petition signatures outside a polling place on election day?

Not within 250 feet of the primary entrance, and not inside the building, on any day ballots are being cast in person, early voting included. 18-2318 names soliciting signatures for any petition. Adjacent private property is exempt.

Federal versus state

Can a federal PAC give to an Idaho legislative candidate?

Yes, within Idaho's limits. Under Guidance 2026-4 it need not register in Idaho if the check comes from its own federal account, it is current with the FEC, and the money is not earmarked for an Idaho race. The candidate lists the PAC's FEC ID.

Can my company give to a congressional candidate?

No. Federal law bars corporate and union treasury gifts to federal candidates, and Idaho's permissive rule does not reach federal races because 52 U.S.C. 30143 preempts state law there. A company may sponsor a federal PAC instead (lesson 4).

My neighbor has a green card. Can she give?

Yes. Lawful permanent residents are outside the definition of foreign national in both 67-6610D and 52 U.S.C. 30121. A visitor on a temporary visa may not give to anyone, measures included; in Idaho a knowing and willful violation over $1,000 in 12 months is a felony.

Timing

When does my $1,000 limit reset?

The primary and general each carry their own limit, so once the primary passes, every donor may give again for the general. The limit is per election, not per calendar year, and it does not reset for a second gift in the same election.

If my candidate loses the primary, what happens to the general-election check I already gave?

It goes back. The Disclosure Manual lets candidates take general money early but requires it to be returned if the candidate loses the primary (lesson 2).

Can I give after the election to help pay off a candidate's debt?

Yes, within that election's limit, counting what you already gave, and only toward debt on the reports through the post-election period (67-6610B). If you gave $500 for the general, you may give up to $500 more toward its debt.

Can a candidate give leftover money to a nonprofit?

Yes, to any organization described in section 170(c) of the Internal Revenue Code, which takes in 501(c)(3) charities, under 67-6610C(1)(c). A gift to another kind of nonprofit falls under "any other lawful purpose." The money may never go into the candidate's pocket (lesson 3).

Local advocacy groups: voter guides, scorecards and endorsements

Community and regional citizen groups print most of the voter guides Idaho voters see. The law sorts them by what they pay for and what the piece says. A five-member group follows the same rules as a statewide one.

When does a group that publishes voter guides become an Idaho political committee?

Under 67-6602(14), when it is specifically designated to support or oppose a candidate or measure, at any dollar amount, or when it takes contributions and spends more than $1,000 in a calendar year to support or oppose candidates or measures. A group active only in local races files its first report after $500 (designated) or $1,000 (general purpose) under 67-6608, then every scheduled report. A truly neutral guide does not support or oppose anyone; endorsements, slate cards and graded scorecards do.

Our group sends questionnaires to every candidate. Does that create any filing?

Sending the questionnaire costs nothing reportable. Publishing the answers costs money, and the classification then turns on what the published guide says and when it lands, as the next two answers explain.

When is a voter guide an independent expenditure?

When it expressly advocates: "vote for," "elect," "defeat," a recommended slate, a list of endorsed candidates. More than $100 for or against any one candidate or measure means 67-6611 statements, and the guide must not be planned with any candidate, or its cost becomes an in-kind gift to that candidate.

When is it an electioneering communication, and when is it neither?

A guide that names candidates, goes out within 30 days of a primary or 60 days of a general, and reaches their voters fits the 67-6602(6) definition even if it endorses no one; the statute has no voter guide exemption. Spending over $100 means a 67-6628 statement listing donors of $50 or more. It is neither when it carries no express advocacy and goes out outside the windows, or when a membership group sends it only to its members and their families, which the definition excludes.

Can a 501(c)(3) publish a voter guide or scorecard?

Only a truly nonpartisan one. In Rev. Rul. 78-248 the IRS allowed a voting record of all members on a wide range of subjects with no editorial opinion, and a questionnaire to all candidates on a broad set of issues. It barred a questionnaire with biased questions and a narrow-issue voting record widely distributed during a campaign. Rev. Rul. 2007-41 restates the test, asking whether a guide shows "a bias or preference in content or structure," and points to Rev. Rul. 80-282 on timing and distribution. Report cards, grades and endorsements are off the table for a charity.

What about a 501(c)(4), an LLC or an unincorporated association?

A (c)(4) may endorse and publish scorecards as long as campaign work is not its primary activity, and 527(f) may tax the candidate spending. An LLC or an association with no tax exemption faces no IRS political limit, though an association organized mainly to influence elections is a 527 political organization "whether or not incorporated" under 26 U.S.C. 527(e)(1). In Idaho all of them are "persons" under the same triggers, and a nonprofit association that is not a PAC owes a 67-6606 statement past $1,000.

What disclaimer goes on the printed guide?

67-6614A requires that "the person responsible" be "clearly indicated" on communications expressly advocating for or against a candidate or measure, so every endorsement card, slate and advocacy scorecard carries "Paid for by" and the group's registered name. The statute's text reaches express advocacy, but put the line on a neutral guide too; it costs one line and answers the first question any complaint will ask (lesson 6).

Must the group disclose its donors?

It depends on its box. As a registered PAC: every contributor over $50. As a nonbusiness entity spending its general funds past $1,000: everyone who paid it more than $500 in either of the two prior years, or paid or agreed to pay more than $500 in the current year, under 67-6606. As an electioneering filer: contributors of $50 or more. An independent expenditure statement alone lists vendors, not donors. Guidance 2026-5 recommends the PAC route.

What happens to a group that gets it wrong?

Civil fines under 67-6625 run up to $250 for an individual and $2,500 for any other person, and knowing and willful violations are misdemeanors. In 2024 the Secretary of State fined a southern Idaho group $1,000 and ordered it to stop distributing its voter guides until it complied, because it had paid for them without registering as a political committee (lesson 11).

One group, two entities: a club and its PAC

Many local groups run as a pair: a club or association with members and dues, and a PAC with a similar name that does the election spending. The pair works when the two are kept apart on paper and in the bank.

Entity type	IRS form filed	May support candidates?	May give to the PAC?	Donor disclosure
501(c)(3) charity	Form 990 series	No	Only to a measure-only committee, as lobbying	Schedule B names to the IRS, not public; Idaho 67-6606 past $1,000
501(c)(4) social welfare group	Form 990 series; Form 8976 notice	Some, if not primary activity; 527(f) tax	Yes	Not public at the IRS; Idaho 67-6606 past $1,000
501(c)(6) business league	Form 990 series	Some, if not primary activity; 527(f); dues notice or proxy tax	Yes	Same as (c)(4)
501(c)(7) social club	Form 990 series; Form 990-T at $1,000 or more of unrelated income	Only incidentally; substantially all activity must be social; 527(f)	Yes, in small amounts	Same as (c)(4)
Unincorporated association, not exempt	Ordinary income tax filings; 527 rules if mainly political	Yes	Yes	Idaho 67-6606 past $1,000 if nonbusiness
LLC	Ordinary business tax filings	Yes	Yes	Owners not listed; it appears as the giver
The PAC	Form 8871 and 8872 unless exempt; Idaho Sunshine reports	Yes; that is its job	Not applicable	Every contributor over $50 on Sunshine

What may a 501(c)(4) or 501(c)(6) club do in elections itself?

Some candidate work, so long as it is not the primary activity, and any spending on candidates, made "directly (or through another organization)," is subject to the tax in 26 U.S.C. 527(f) on the lesser of net investment income or the amount spent. A gift to the club's PAC counts as spending through another organization. Measure work falls outside 527(f), since its exempt function is about electing people.

And a 501(c)(7) social club?

Less. Section 501(c)(7) covers clubs organized for pleasure and recreation, "substantially all of the activities of which" are for those purposes, so politics can only be a sideline. The IRS lets up to 35 percent of gross receipts come from outside sources, investment income included, and no more than 15 percent from nonmember use of facilities; nonmember and investment income is generally taxed. The IRS social club page does not address political activity directly, and 527(f) applies to any 501(c) group. A club planning real election spending should put it in the PAC.

How is the PAC classified?

In Idaho it is a political committee registered with the Secretary of State, with its own treasurer, account and reports. For federal tax purposes a PAC that works on candidates is usually a 527 political organization; a measure-only committee is a harder case, because the 527(e)(2) "exempt function" covers only the selection of individuals for office. Under 527(i) it gives the IRS Form 8871 notice within 24 hours of being established unless it reasonably expects less than $25,000 in gross receipts a year, or is a state or local candidate or party committee. Under 527(j) it is excused from Form 8872 reports if it is that small, or if it qualifies as a "qualified state or local political organization" under 527(e)(5): its exempt functions are solely state and local races, it reports each contribution and expenditure under state law, the state makes those reports public, and the organization itself makes them available for public inspection. Confirm that status with the IRS before relying on it.

Can the club give dues money to the PAC?

Yes, unless the club is a 501(c)(3) and the PAC backs candidates. The PAC reports the club as a contributor by name and address. For the club, Guidance 2026-5 counts contributions to an Idaho PAC toward the $1,000 trigger, so a club that gives more than $1,000 in a year files a 67-6606 statement naming members and donors who paid it more than $500. Members who want their names off that list give to the PAC directly.

Can the club pay the PAC's rent, staff or mailing costs?

Yes, and each is an in-kind contribution at fair market value under 67-6610A(5), reported by the PAC. Guidance 2026-5 counts donated space and in-kind items toward the club's $1,000 trigger. It does not mention staff time, but Guidance 2026-6 treats paid staff services an organization provides to a political committee as an in-kind contribution, and the same reasoning fits a club. Letting the PAC solicit or hand out materials at club meetings is allowed if the money stays separate.

Can the PAC pay the club?

Yes, for real goods or services at fair value, such as renting the hall or the mailing list, reported as an expenditure to the club with its purpose. PAC money may not be "converted by any person to personal use" under 67-6610C(2)(a), so it never ends up with officers.

A member hands the club a check and says "this is for the PAC." What now?

Treat it as the member's contribution to the PAC: pass the check through uncashed, or have the member write a new one to the PAC, and the PAC reports the member. Running it through the club's account and reporting the club would hide the source, which 67-6614 bars, and a club that collects money for political purposes and spends more than $1,000 risks becoming a political committee itself.

May the two share a name, logo, website, email list, officers or bank account?

Never a bank account: committee funds must be segregated and not commingled under 67-6604(2). Similar names and shared officers are lawful, but under 67-6610A(6)(c) two entities that share most of a board or two or more officers count as one contributor to candidates. Guidance 2026-5 says emails to members and unpaid social media posts generally need no report. Guidance 2026-6 lists sponsored or boosted content and added production costs as paid activity to track, so a boosted post or a website section the club pays to build for the PAC is an in-kind gift.

Can a 501(c)(3) be the club half of a pair?

Not with a PAC that backs or fights candidates. The IRS says a 501(c)(3) may not contribute to such a PAC or "establish and maintain" its own separate segregated fund, so no charity can sponsor a candidate PAC (lesson 8). A charity may pair with a measure-only committee, counted as lobbying.

What mistakes trip up club-and-PAC pairs?

The club pays for voter guides that should have been the PAC's, as the 2024 southern Idaho group did before its $1,000 fine. Dues and PAC checks land in one account. The PAC's mailer goes out with the club's name and no "paid for by" line. And the club gives the PAC more than $1,000 without filing the 67-6606 statement it owes.

Hard questions

Why can a Super PAC take unlimited money when I can only give a legislative candidate $1,000?

Because the courts treat a gift to a candidate and spending by someone else differently. Since Buckley v. Valeo (1976), limits on gifts to candidates have been upheld to prevent corruption or its appearance, which is why 67-6610A caps yours at $1,000 per election. In Citizens United v. FEC (2010), the U.S. Supreme Court held that independent spending does not give rise to that kind of corruption, and lower courts then struck limits on gifts to groups that only spend independently, as lesson 4 explains. Defenders say a group that cannot coordinate with a candidate cannot buy one. Skeptics answer that a candidate knows exactly who funded the group running ads for her. The law's answer, for now, is disclosure and a coordination rule, not a cap.

Why is there no limit on gifts to ballot measure committees?

Because no officeholder is on the ballot to be bought. In Citizens Against Rent Control v. City of Berkeley (1981), the U.S. Supreme Court struck a $250 cap on gifts to measure committees, reasoning that the quid pro quo risk behind candidate limits is absent when voters decide an issue directly, and that public disclosure of contributors protects the process. Idaho follows that rule: measure committees take unlimited money and report every contributor over $50. People worried about outside money in initiatives argue that a single large donor can still dominate a campaign, and the Proposition 1 and open primaries totals in lesson 11 show how much money a measure can draw. The constitutional answer has been more disclosure, not limits.

Isn't putting a small club's members on a public list just a way to expose people to harassment?

It can feel that way to a dues-paying member of a five-person group, and the U.S. Supreme Court has drawn limits. In Americans for Prosperity Foundation v. Bonta (2021), it struck down California's blanket demand for charities' major-donor lists, holding that disclosure rules must be narrowly tailored to the government's interest. Idaho's 67-6606 is narrower than that: it applies only after a nonbusiness entity spends more than $1,000 on Idaho elections, and only to people who paid it more than $500. And members who want off the club's list can give to the PAC directly, where the list is the PAC's donors, not the club's. Supporters of the rule say voters reading a club's mailer should be able to see who pays for it.

Doesn't a club-and-PAC pair just let people hide who is really paying?

It can be abused that way, which is why Idaho attaches three rules to the pair. Money given through someone else to hide its source is barred by 67-6614. A club that gives the PAC more than $1,000 owes a 67-6606 statement naming its own large donors. And entities sharing most of a board or two or more officers count as one contributor to candidates under 67-6610A(6)(c). The gap that remains is the LLC: its gift appears under the LLC's name, and nothing on the PAC's report lists who owns it. Lesson 10 shows how to trace one.

Why may a permanent resident give when a foreign worker living next door may not?

Because the ban turns on citizenship and permanent residence, not on where someone lives or pays taxes. Under 52 U.S.C. 30121 and Idaho's 67-6610D, foreign nationals may not give or spend in U.S. elections, and in Idaho the ban reaches ballot measures too. A lawful permanent resident is outside the definition and may give like a citizen. A worker on a temporary visa who has lived in Idaho for years is inside it. Supporters of the line say self-government means people with a permanent stake decide elections. Others find it hard to explain to a neighbor who pays Idaho property tax. Congress and the Legislature drew it where it is, and in Idaho a knowing and willful violation over $1,000 in 12 months is a felony.

Pictures, Numbers and Infographics

The diagram shows the main flows. Solid lines are allowed, with limits on any line that ends at a candidate. Dashed lines are barred.

Figure	Amount	Source
Limit per giver, per election: legislative, judicial, local candidates	$1,000	Idaho Code 67-6610A(1)
Limit per giver, per election: statewide candidates	$5,000	67-6610A(1)
Party limits: legislative; statewide (state central committee)	$2,000; $10,000	67-6610A(2)
Political committee trigger; county party trigger	Over $1,000; over $5,000 in expenditures	67-6602(14)
Independent expenditure and electioneering statement trigger	Over $100	67-6611; 67-6628
Nonbusiness entity statement: spending trigger; payers named	Over $1,000; over $500	67-6606
48-hour notice for a contribution	$1,000 or more, any time	67-6607(3)
Electioneering windows	30 days before a primary; 60 before a general	67-6602(6)
Polling place buffer	250 feet, every in-person voting day	18-2318
Form 8871 receipts threshold	$25,000 a year	26 U.S.C. 527(i)
Social club outside income; nonmember use of facilities	Up to 35 percent; up to 15 percent	IRS social clubs page