The relevant language in IRS Publication 561 is "If you receive a benefit as a result of making a contribution to a qualified organization...."
In this case, that means that, even though other people might be invited for other reasons, if a particular donor was invited because of their giving, the benefit represents a quid pro quo.
There is also a presumption that, when a benefit is provided, no portion of a gift is deductible, so the burden would be on your organization to demonstrate that a particular donor was not invited because of their giving. That's a pretty high lift if, for example, you invite all donors at a certain level, all donors to this program at a certain level, all local donors to the program at a certain level, etc.
My US$0.02 worth; the usual disclaimers apply.
Good luck!
Alan
Alan S. Hejnal (he/him/his)
Data Quality Manager
