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A political action committee [PAC] that is not controlled by an organization
employing a lobbyist, either in law or in fact, may, consistent with laws
administered by the Board, make a campaign contribution at any time.

A political action committee controlled, either in law or in fact, by an organization
employing a lobbyist may make a campaign contribution only when
Wisconsin's lobbying laws permit a lobbying principal to contribute directly.
Thus, a PAC controlled by a lobbying principal may contribute to a partisan
elective state official or to a candidate for election to a partisan state office or
to the personal campaign committee of either only in the year of the candidate's
election between June 1 and the the day of the general election (and, in
the case of a candidate for legislative office, only if the legislature has
concluded its final floorperiod, and is not in special or extraordinary session).

Because the Ethics Board has not previously had an opportunity to address
this point, the Board does not intend to prosecute a complaint against any
principal which may, in the past, have made, via a PAC, a campaign contribution
during a period in which the principal could not contribute.
OEB 92-27

July 9, 1992