And if Giuliani is not with a firm, then it seems it need not be reported. See the fourth question/answer https://transition.fec.gov/pages/brochures/volunteer_activity_brochure.pdf …
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If it is service to a campaign (rather than to the president not in his campaign capacity) it has to be reported, but it is not a contribution subject to contribution limits See third question/answer here: https://transition.fec.gov/pages/brochures/volunteer_activity_brochure.pdf …https://twitter.com/CelesteKatzNYC/status/997300911872593921 …
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Does he need to report as in-kind contributions the bullets he keeps firing into his own feet?
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