Applies To: Federal Election Commission, New Jersey Election Law Enforcement Commission
Partnerships and LLCs have special reporting rules because a contribution from one is attributed to the entity’s partners or members. How the contribution is reported depends on the filing agency. In ISP, the data entry is the same either way: the contribution is entered once, from the partnership, with each partner’s share added as splits.
How do I enter the contribution?
- On the partnership’s entity record, set the Business Type to Partnership, LLC, or LLP.
- Add a Monetary Contribution from the partnership for the full amount of the check.
- In the Specify Splits section, add a split for each partner or member with their share of the contribution.
- Be sure to collect each partner’s Occupation and Employer, since partner information is included in reporting.
If a contribution from an entity marked as a Partnership, LLC, or LLP has no splits, the compliance report will show an error, since the partner share detail is required.
How does this report to the FEC?
For federal reports, a partnership contribution is attributed to both the partnership and each partner, per 11 CFR 110.1(e). The partnership has its own contribution limit, and each partner’s share counts against that partner’s individual limit.
On the FEC report, the partnership is itemized at the full contribution amount, and each partner’s share appears as a memo entry showing the split from the partnership. Memo entries do not affect totals, so the contribution is only counted once.
An LLC is treated as a partnership for contribution purposes unless it has elected to be taxed as a corporation. A single-member LLC that has not made that election is attributed entirely to that member. For full details, see the FEC’s guidance on partnership and LLC contributions.
How does this report to New Jersey?
New Jersey does not allow a partnership or LLC to make a contribution as an entity. Per N.J.A.C. 19:25-11.10, the contribution must be allocated to the contributing partners or members, so only the partner splits are reported, not the partnership itself. The same data entry above produces this result automatically.
For details on how transactions pull to each line of the FEC Form 3, see How Do I Pull a Transaction to a Specific Line on the FEC Form 3?
