Like Citizens for a Sound Economy [CSE], the new group had several different divisions, with different tax structures. One wing of the new organization was the Americas for Prosperity Foundation, whose board members included both David Koch and Richard Fink. The foundation was a 501(c)(3) educational organization, so donations to it could be written off as tax deductible charitable gifts. But while it could "educate" the public, it could not participate in electoral politics. The other division was an advocacy organization, just called Americans for Prosperity. Under the tax code, it was a 501(c)(4) "social welfare" group, which meant that is could participate in electoral politics so long as this was not its "primary" activity. Donations to this side of the organization could also be made in secret but were not tax deductible. (200)