That is a good question to which I cannot give a definitive answer.  We have not been able to find an IRS ruling on the issue.

Lobbying generally means taking a position on “legislation.” Legislation is defined in the Regulations implementing the expenditure tests under Section 501(h) (See Ready Reference Pages: “Should Your Organization Elect Under 501(h)?” and “How to Figure Lobbying Limits Under 501(h).”), to “include” “action by Congress, any state legislature, any local council, or similar legislative body….”  Legislative “action” is limited to “the introduction, amendment, defeat or repeal of acts, bills, resolutions, or similar items.”

Legislation includes proposed international treaties submitted to the Senate for its advice and consent, and the IRS has interpreted the Regulation to include lobbying on Senate approval of judicial nominees as legislative action.  The IRS has also ruled that lobbying on legislation in other countries is considered lobbying under the statute.

The question then appears to be whether the IRS would consider the United Nations essentially equivalent to another country.  Its Resolutions sometimes provide a basis to go to war, but is it a governmental entity?

It would be only speculation to suggest how the IRS would answer the question.  To be conservative and safe, it probably makes sense to conduct the organization’s operations so that even if the activity would be considered lobbying, it would be within the permitted limits.  If an organization expects to exceed the limits, it may want to ask for a ruling.

If any reader has a different answer to this question, we would be pleased to hear it.