The Internal Revenue Service (IRS) has published an updated staff training manual on election year activities by exempt organizations, including 501(c)(3) charitable and educational organizations and political committees exempt under Section 527. The last manual was published in FY 1993. While this Continuing Education Program (CEP) manual cannot be cited as a legal authority, it contains a rich store of information on the law and provides the public with the same guidance used by IRS staff. The Question and Answer format covers the history of restrictions on electoral activity, sanctions, allowable activity for 501(c)(3)s and activities of individuals associated with them, relationships between 501(c)(3)s and political committees, and reporting for Section 527 political committees. The full text is online here. The CPE text addressed some new issues, including issue advocacy and educational activity. The manual suggests that "more than just a positive or negative correspondence between an organization's position and a candidate's position" is required for a finding of [prohibited] campaign intervention in an issue advertisement, noting that there must be "some reasonably overt indication" of support or opposition. The focus is whether a statement focuses on the issue or the candidate. To distinguish between educational materials that express a viewpoint on an issue and electioneering statements, the text suggests four factors be considered: 1.) whether the a significant portion of the communication is unsupported by fact, 2.) distorted facts are cited, 3.) the communication contains inflammatory and disparaging terms and conclusions based on emotion instead of objective analysis, and 4.) the approach does not take the audience's background or training into account. As always with IRS rules on electioneering, the facts and circumstances surrounding a communication or activity are used to determine if a violation of the prohibition for 501(c)(3) organizations has occurred. The 2000 law requiring filing and disclosure by Section 527 political committees is reviewed in detail in the text, including treatment of separate segregated funds of 501(c)(4) organizations. The appendix includes examples of permissible and impermissible affiliations between charities, social welfare organizations and PACs. Another chapter of the CPE text addresses accuracy in reporting on IRS Form 990, the annual information return for exempt organizations. The text of that chapter can be found here. Click here for the entire CPE text.