PNW Wolf Pack By-Laws

Religious Institution (church et al.)- ByLaws of the PNW Wolf Pack.

• The Pacifc Northwest Wolfpack is organized and operated exclusively for religious, educational, scientific and other charitable purposes;
• Pacifc Northwest Wolfpack net earnings will not inure to the benefit of any private individual or shareholder;
• No substantial part of Pacifc Northwest Wolfpack activity may be attempting to influence legislation;
• The Pacifc Northwest Wolfpack does not intervene in political campaigns; and
• The Pacifc Northwest Wolfpack purposes and activities may not be illegal or violate fundamental public policy.

Inurement to Insiders
Pacifc Northwest Wolfpack, like all exempt organizations under IRC
Section 501(c)(3), are prohibited from engaging in activities that result in inurement of the church’s or organization’s income or assets to insiders (such as persons having a personal and private interest in the activities of the organization). Insiders could include the Gothi/Gydija, church board members, officers, and in certain circumstances, employees. Examples of prohibited inurement include the payment of dividends, the payment of unreasonable compensation to insiders and transferring property to insiders for less than fair market value. The prohibition against inurement to insiders is absolute; therefore, any amount of inurement is, potentially, grounds for loss of tax-exempt status. In addition, the insider involved may be subject to excise tax. Any member of Pacifc Northwest Wolfpack found to be responsible for inurement to insiders will be given a fair hearing before the law speaker. If found responsible that member will be removed from the pack and stripped of any title or recognition. (Note that prohibited inurement doesn’t include reasonable payments for services rendered, payments that further tax-exempt purposes or payments made for the fair market value of real or personal property.)

Private Benefit

Pacifc Northwest Wolfpack’s activities must be directed exclusively toward charitable, educational, religious or other exempt purposes. The Pacifc Northwest Wolfpack’s activities may not serve the private interests of any individual or organization. Rather, beneficiaries of an organization’s activities must be recognized objects of charity (such as the poor or the distressed) or the community at large (for example, through the conduct of religious services or the promotion of religion). Private benefit is different from inurement to insiders. Private benefit may occur even if the persons benefited are not insiders. Also, private benefit must be substantial to jeopardize tax-exempt status.

Substantial Lobbying Activity

No substantial part of Pacifc Northwest Wolfpack’s activities will attempt to influence legislation (commonly known as lobbying). Pacifc Northwest Wolfpack may engage in some lobbying, but too much lobbying activity risks loss of tax-exempt status. Legislation includes action by Congress, any state legislature, any local council or similar governing body, with respect to acts, bills, resolutions or similar items (such as legislative confirmation of appointive offices), or by the public in a referendum, ballot initiative, constitutional amendment or similar procedure. It doesn’t include actions by executive, judicial or administrative bodies. Pacifc Northwest Wolfpack will not attempt to influence legislation by contacting, or urging the public to contact, members or employees of a legislative body for the purpose of proposing, supporting or opposing legislation.

The Pacifc Northwest Wolfpack wiil not advocate the adoption or rejection of legislation. Pacifc Northwest Wolfpack may, however, involve themselves in issues of public policy without the activity being considered as lobbying. For example, Pacifc Northwest Wolfpack may conduct educational meetings, prepare and distribute educational materials, or otherwise consider public policy issues in an educational manner.

Measuring Lobbying Activity

Substantial part test. Whether a church’s or religious organization’s attempts to
influence legislation constitute a substantial part of its overall activities is determined on the basis of all the pertinent facts and circumstances in each case. The IRS considers a variety of factors, including the time devoted (by both compensated and volunteer workers) and the expenditures devoted by the organization to the activity, when determining whether the lobbying activity is substantial.

Churches must use the substantial part test since they aren’t eligible to use the
expenditure test. Under the substantial part test, a church or religious organization that conducts excessive lobbying activity in any taxable year may lose its tax-exempt status, resulting in all its income being subject to tax. In addition, a religious organization is subject to an excise tax equal to five percent of its lobbying expenditures for the year in which it ceases to qualify for exemption. Further, a tax equal to five percent of the lobbying expenditures for the year may be imposed against organization managers, jointly and severally, who agree to the making of such expenditures knowing that the expenditures would likely result in loss of tax-exempt status.)

Political Campaign Activity

Pacifc Northwest Wolfpack is absolutely prohibited from directly or
indirectly participating in, or intervening in, any political campaign on behalf of (or in opposition to) any candidate for elective public office. Contributions to political campaign funds or public statements of position (verbal or written) made by or on behalf of the Pacifc Northwest Wolfpack in favor of (or in opposition to) any candidate for public office clearly violate the prohibition against political campaign activity. Violation of this prohibition may result in removal from the Pacifc Northwest Wolfpack after a fair hearing before the law speaker.

Certain voter education activities (including the presentation of public forums and the publication of voter education guides) conducted in a non-partisan manner do not constitute prohibited political campaign activity. In addition, other activities intended to encourage people to participate in the electoral process, such as voter registration and get-out-the-vote drives, would not constitute prohibited political campaign activity if conducted in a non-partisan manner. On the other hand, voter education or registration activities with evidence of bias that: (a) would favor one candidate over another; (b) oppose
a candidate in some manner; or (c) have the effect of favoring a candidate or
group of candidates, will constitute prohibited participation or intervention. Individual Activity by Religious Leaders.

The political campaign activity prohibition in place by the Pacifc Northwest Wolfpack isn’t intended to restrict free expression on political matters by leaders of Kindred Churches or Godar speaking for themselves, as individuals. Nor are leaders prohibited from speaking about important issues of public policy. However, for our church to remain tax exempt under IRC Section 501(c)(3), religious leaders can’t make partisan comments in official organization publications or at official church functions. To avoid potential attribution of their comments outside of church functions and publications, Pacifc Northwest Wolfpack leaders who speak or write in their individual capacity are encouraged to clearly indicate that their comments are personal and not intended to represent the views of the Pacifc Northwest Wolfpack.
Issue Advocacy vs. Political Campaign Intervention.

Like other Section 501(c)(3) organizations, Pacifc Northwest Wolfpack takes positions on public policy issues, including issues that divide candidates in an election for public office. However, Pacifc Northwest Wolfpack must avoid any issue advocacy that functions as political campaign intervention. Even if a statement does not expressly tell an audience to vote for or against a specific candidate, Pacifc Northwest Wolfpack delivering the statement would put us at risk of violating the political campaign intervention prohibition if there is any message favoring or opposing a candidate. No leader or member of the Pacifc Northwest Wolfpack acting as a representative of the Pacifc Northwest Wolfpack will identify a candidate by stating the candidate’s name or by other means such as showing a picture of the candidate, referring to political party affiliations or other distinctive features of a candidate’s platform or biography. Pacifc Northwest Wolfpack strictly prohibits political campaign intervention.

Inviting a Candidate to Speak

Depending on the facts and circumstances, Pacifc Northwest Wolfpack may
invite political candidates to speak at its events. Political candidates may be invited in their capacity as candidates, or individually (not as candidates).

Candidates may also appear without an invitation at organization events that are open to the public.

Speaking as a candidate.

Like any other IRC Section 501(c)(3) church, when a candidate is invited to speak at a Pacifc Northwest Wolfpack event as a political candidate,

• The Pacifc Northwest Wolfpack church provides an equal opportunity to the political candidates seeking the same office.
• The Pacifc Northwest Wolfpack church will not indicate any support of or opposition to the candidate. This will be stated explicitly when the candidate is introduced and in communications concerning the candidate’s appearance.
• Pacifc Northwest Wolfpack will not participate in any political fundraising.
• Whether the individual is chosen to speak solely for reasons other than candidacy for public office,
• Pacifc Northwest Wolfpack maintains a nonpartisan atmosphere on the premises or at any event where a candidate is present, and the Pacifc Northwest Wolfpack clearly indicates the capacity in which the candidate is appearing and must not mention the individual’s political candidacy or the upcoming election in the communications announcing the candidate’s attendance at the event.

Equal opportunity to participate. Like any other Section 501(c)(3) organization, Pacifc Northwest Wolfpack will give candidates an equal opportunity to participate, Pacifc Northwest Wolfpack church will consider the nature of the event to which each candidate is invited, in addition to the manner of presentation. For example, a church or religious organization that invites one candidate to speak at its well attended annual Althing, but invites the opposing candidate to speak at a sparsely attended regional meeting, will likely be found to have violated the political campaign prohibition, even if the manner of presentation for both speakers is otherwise neutral.
Public forum.

Pacifc Northwest Wolfpack may invite several candidates to speak at a public forum. A public forum involving several candidates for public office will be considered an educational activity.

The forum will not be operated to show a bias for or against any candidate.
When Pacifc Northwest Wolfpack invites several candidates to speak at a forum, questions for the candidates will be prepared and presented by an independent nonpartisan panel;

• Topics discussed by the candidates will cover a broad range of issues that the candidates would address if elected to the office sought and are of interest to the public;
• Each candidate will be given an equal opportunity to present his or her views
  on the issues discussed;
• The candidates will be asked to agree or disagree with positions, agendas,
  platforms or statements of the Pacifc Northwest Wolfpack; and
• Moderator comments on the questions will not imply approval
  or disapproval of the candidates.

A candidate may seek to reassure the Pacifc Northwest Wolfpack that it’s permissible for the church to do certain things in connection with the candidate’s appearance.

Pacifc Northwest Wolfpack should keep in mind that the candidate may not
be familiar with the church’s tax-exempt status and that the candidate may
be focused on compliance with the election laws that apply to the candidate’s
campaign rather than the federal tax law that applies to the church. The church will be in the best position to ensure compliance with the prohibition on political campaign intervention if it makes its own independent conclusion about its compliance with federal tax law.

Voter Education, Voter Registration and Get-Out-the-Vote Drives

Pacifc Northwest Wolfpack is permitted to conduct certain voter education
activities (including the presentation of public forums and the publication of voter education guides) if they are carried out in a non-partisan manner. In addition, Pacifc Northwest Wolfpack may encourage people to participate in the electoral process through voter registration and get-out-the-vote drives, conducted in a non-partisan manner. On the other hand, voter education or registration activities conducted in a biased manner that favors (or opposes) one or more candidates is prohibited.

Like other Section 501(c)(3) organizations, Pacifc Northwest Wolfpack undertakes voter education activities by distributing voter guides. Voter guides, generally, are distributed during an election campaign and provide information on how all candidates stand on various issues. These guides may be distributed with the purpose of educating voters; however, they may not be used to attempt to favor or oppose candidates for public elected office. Neutral, unbiased and complete compilation of all candidates’ positions will be included in voter guides distributed by Pacifc Northwest Wolfpack or they will not be distributed.

Websites.

Pacifc Northwest Wolfpack uses their own websites to disseminate statements and information. They also routinely link their websites to websites maintained by other organizations as a way of providing additional information that the Pacifc Northwest Wolfpack believes is relevant to the public. A website is a form of communication. Pacifc Northwest Wolfpack will not post something on its website that favors or opposes a candidate for public office.

Pacifc Northwest Wolfpack has control over whether it establishes a link to another site. When Pacifc Northwest Wolfpack establishes a link to another website, the organization is responsible for the consequences of establishing and maintaining that link, even if the organization doesn’t have control over the content of the linked site. Because the linked content may change over time, the Pacifc Northwest Wolfpack will reduce the risk of political campaign intervention by monitoring the linked content and adjusting the links accordingly.

Consequences of Political Campaign Activity

When Pacifc Northwest Wolfpack participates in political campaign activity, it jeopardizes both its tax-exempt status under IRC Section 501(c)(3) and its eligibility to receive tax-deductible contributions. In addition, it may become subject to an excise tax on its political expenditures. This excise tax may be imposed in addition to revocation, or it may be imposed instead of revocation. Also, the church or religious organization should correct the violation.
(Excise tax. An initial tax is imposed on an organization at the rate of 10 percent of the political expenditures. Also, a tax at the rate of 2.5 percent of the expenditures is imposed against the organization managers (jointly and severally) who, without reasonable cause, agreed to the expenditures knowing they were political expenditures. The tax on management may not exceed $5,000 with respect to any one expenditure.

In any case in which an initial tax is imposed against an organization, and the
expenditures are not corrected within the period allowed by law, an additional tax equal to 100 percent of the expenditures is imposed against the organization. In that case, an additional tax is also imposed against the organization managers (jointly and severally) who refused to agree to make the correction. The additional tax on management is equal to 50 percent of the expenditures and may not exceed $10,000 with respect to any one expenditure. Correction. Correction of a political expenditure requires the recovery of the expenditure, to the extent possible, and establishment of safeguards to prevent future political expenditures.

Please note that a church or religious organization that engages in any political
campaign activity also needs to determine whether it complies with the appropriate federal, state or local election laws, as these may differ from the requirements under IRC Section 501(c)(3).)

Pacifc Northwest Wolfpack, like other tax-exempt organizations, may engage in income-producing activities unrelated to their tax-exempt purposes, as long as the unrelated activities aren’t a substantial part of Pacifc Northwest Wolfpack activities. However, the net income from these activities will be subject to the

Unrelated Business Income Tax (UBIT)if the following three conditions are met:

• The activity constitutes a trade or business,
• The trade or business is regularly carried on, and
• The trade or business is not substantially related to the organization’s exempt purpose. (The fact that the organization uses the income to further its charitable or religious purposes does not make the activity substantially related to its exempt purposes.)

Exceptions to UBIT

If it meets one of the following exceptions: (a) substantially all the work in operating the trade or business is performed by volunteers, (b) the activity is conducted by the organization primarily for the convenience of its members or (c) the trade or business involves the selling of merchandise substantially all of which was donated.

Sale of merchandise and publications The sale of merchandise and publications (including the actual publication of materials) must have a substantial relationship to the exempt purposes of thePacifc Northwest Wolfpack organization.

Recordkeeping Requirements Books of Accounting and Other Types of Records

All tax-exempt organizations, including churches and religious organizations (regardless of whether tax-exempt status has been officially recognized by the IRS), are required to maintain books of accounting and other records necessary to justify their claim for exemption in the event of an audit. See Special Rules Limiting IRS Authority to Audit a Church. Tax-exempt organizations are also required to maintain books and records that are necessary to accurately file any federal tax and information returns that may be required. There is no specific format for keeping records. However, the types of required records frequently include organizing documents (charter, constitution, articles of incorporation) and bylaws, minute books, property records, general ledgers, receipts and disbursements journals, payroll records, banking records and invoices. The extent of the records necessary generally varies according to the type, size and complexity of the organization’s activities. 26 Length of Time to Retain Records The law does not specify a length of time that records must be retained; however, the following guidelines should be applied in the event that the records may be material to the administration of any federal tax law. TYPE OF RECORD LENGTH OF TIME TO RETAIN Records of revenue Retain for at least four and expenses, years after filing the including payroll returns to which they records. relate. Records relating to Retain for at least four acquisition and years after the filing of disposition of property the return for the year (real and personal, in which disposition including investments). occurs.