Our 501(c)(6) veterans business organization recently attended, along with other veterans organizations, a "meet and greet" with a mayoral candidate. We paid one of our members to photograph our attendance at the event. Is there any way this could be considered political activity that could cost us our exemption if these photos are just going into our archives, might someday appear in our newsletter, but are not being used except for souvenirs for the veterans in our organization?
No. Unlike a 501(c)(3) charitable organization, which can lose its exempt status for participating in an election campaign, a 501(c)(6) trade association is not prohibited from supporting or opposing candidates so long as it is not the primary activity of the organization. The U.S. Chamber of Commerce, for example, was reported to have spent more than $30 million in independent political campaign expenditures during the 2010 mid-term elections.
Even if your organization were a charity, however, merely having your picture taken with a candidate and putting it in the archive or keeping it as a personal souvenir would not be likely to rise to the level of a participation in a campaign. Publishing such a picture in your official newsletter, however, could be deemed by the IRS to have crossed the line. (See Ready Reference Page: “IRS Issues New Guidance on Electioneering.”)