June 16, 2014 •
Ask the Experts – LDA Tracking and Reporting
A. The LDA does not contain any special tracking requirements for reporting expenditures. Registrants employing in-house lobbyists are required to provide a “good faith estimate of the total expenses” of their lobbying activities. With the “good faith” standard as the back drop, an organization should determine whether including 100 percent of their lobbyists’ compensation meets that standard. Aside from the tax implications of including 100percent of compensation, typically, there is some time that is spent during the course of a quarter that is not defined as lobbying and varies from month to month depending on what issues are being addressed. Therefore, providing a good faith estimate, in most cases, will require a registrant to implement some sort of tracking process to meet the standard. In the event of an audit, the ability to demonstrate reasonable efforts to track and capture lobbying activity, and only lobbying activity, is an additional benefit.
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