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related advocacy may include a variety of combinations of different kinds of tax-exempt
organizations. The combination we analyze in this paper is the commonly used arrangement of
a 501(c)(3) charity, a 501(c)(4) social welfare organization, and a connected political action
committee (PAC).
Little research has been conducted on complex organizational structures in general and
their relation to advocacy in particular. Indeed, nonprofits are mostly studied as solo
organizations or as policy networks and coalitions, rather than as complex organizational
structures. An initial review of the nonprofit literature revealed that even research on hybrid
organizations (those that combine both service and advocacy provisions) (Minkoff, 2002) gives
only passing mention of complex organizational structures as a means to further advocacy ends.
Boris and Krehely (2002), in an overview of civic participation and advocacy in the nonprofit
sector, also only identify the existence of “complex multiple-organization conglomerates”
organized to take advantage of the legal benefits of different types of nonprofits. Studies of
interest group strategies and tactics rarely consider how legally separate but functionally and
financially related organizations determine what finances from which part of the structure will
support political activities and the consequences of these internal arrangements for advocacy.
This paper examines how regulatory policy shapes the formation and operation of
complex organizational structures as organizational systems geared toward political advocacy.
We examine the components of complex organizational structures and the programmatic and
financial relationships permissible under regulatory policy. Using information derived from
forms nonprofits file with the Internal Revenue Service (IRS) and the Federal Election
Commission (FEC), we model types of fiscal and program relationships that exist among
components of environmental groups with complex organizational structures. The results allow
Convention