Measuring Lobbying Activity: Substantial Part Test

This is the standard that the IRS applies if a nonprofit organization has not elected to use the “Expenditure Test." Whether an organization’s attempts to influence legislation, i.e., lobbying, 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.