501(c)(3) Status and Political Campaign Trainings 

Under federal tax law, a 501(c)(3) organization may ʻnot participate in, or intervene in (including the
publishing or distributing of statements), any political campaign on behalf of (or in opposition to) any candidate for public office.’ 501(c)(3)s can, however, participate in those electoral activities that do not support or oppose candidates for public office (ʻnonpartisan electoral activities’).
— Internal Revenue Code 501(c)(3)

The Kuleana Academy is modeled after similar national and statewide programs sponsored by other 501(c)(3) organizations (see examples listed below).   

While 501(c)(3) organizations may not participate in political campaigns, under federal tax law "501(c)(3)s can, however, participate in those electoral activities that do not support or oppose candidates for public office (ʻnonpartisan electoral activities’).”  

For example, the conduct of certain voter education activities (including the presentation of public forums and the publication of voter education guides) in a non-partisan manner do not constitute prohibited political campaign activity. Other activities intended to encourage people to participate in the electoral process, such as voter registration and get-out-the-vote drives, would not constitute prohibited political campaign activity if conducted in a non-partisan manner. 
~ IRS "Compliance Guide for 501(c)(3) Public Charities"

H.A.P.A.'s Kuleana Academy is not an electoral activity; it is a non-partisan educational program. H.A.P.A. and the Kuleana Academy will not:

  • endorse any political candidates for public office.
  • make any campaign contributions (monetary or in-kind).
  • ask candidates to sign pledges on any issues.

A review of IRS decision and guides, as well as other nonprofit expert sources, shows that 501(c)(3)s can run candidate training (educational) programs as long as they are:

  1. Non-partisan
  2. Available to the public to apply
  3. Not for a "private benefit" to a person/organization [1]
  4. Not helping a specific candidate with his or her campaign

The Kuleana Academy will comply with all of these parameters.  Please see the following resources, source links, and list of other candidate training programs that are currently being conducted by other 501(c)(3) organizations.


From "The Rules of the Game: A Guide to Election-Related Activities for 501(c)(3) Organizations" (Second Edition) (at p.51), by the Alliance for Justice:

Many 501(c)(3) organizations are devoted to educational activities, or use public education as a central means for achieving their goals. So it is not surprising that some 501(c)(3) organizations approach activists and voters from an educational perspective, creating programs to teach people the mechanics of registering to vote and voting, teach activists how to run campaigns and even how to run for office. 
[According to federal tax law], 501(c)(3) groups may sponsor programs to train voters, campaign workers, and candidates, so long as the programs are thoroughly nonpartisan in their recruitment of instructors and students, curriculum, placement of graduates, and all other aspects of operation. . . . 
A 501(c)(3) may target programs at certain groups that have been (and continue to be) underrepresented in the political life of our country, such as low-income voters, racial or ethnic minorities, disabled people, and (at least for now) women, following the same principles the IRS applies for voter registration and [Get Out The Vote] campaigns. . . . [A] 501(c)(3) should not refuse to train activists based on their political party or views on issues. Training potential future candidates on how to get elected must stop before it crosses over into helping a specific candidate in his or her campaign. [2]

More information:

IRS Publication "Election Year Issues" http://www.irs.gov/pub/irs-tege/eotopici02.pdf. In particular, see discussion of American Campaign Academy v. Commissioner, 92 T.C. 1053 (1989), at p. 452.

IRS "Compliance Guide for 501(c)(3) Public Charities" http://www.irs.gov/pub/irs-pdf/p4221pc.pdf

A Primer on How to Avoid the Pitfalls of Electioneering from a Tax Perspective by MacGuireWoods Law Firm.

Election Checklist for 501(c)(3) Public Charities: Ensuring Election Year Advocacy Efforts Remain Nonpartisan  by Bolder Advocacy.

Examples of other 501(c)(3) Campaign and Political Leadership Trainings 

The National Democratic Institute
The National Democratic Institute is a nonprofit, nonpartisan organization working to support and strengthen democratic institutions worldwide through citizen participation, openness and accountability in government. NDI is a 501(c)(3) nonprofit. [3]

Wellstone: Campus Camp Wellstone and Movement Building Project
Progressive political action training, candidate and campaign training. 
Programs are funded by Wellstone Action Fund, which is a 501(c)(3) nonprofit. [4]

Congressional Black Caucus Foundation
Leadership development, public service and public policy training. Congressional Fellows Program, Emerging Leaders Internship Program. CBCF is a 501(c)(3) nonprofit. [5]

The New Leaders Council Institute is the premier leadership and professional development, training, mentoring, networking, and career and political advancement program for young professionals. New Leaders Council is a 501(c)(3) nonprofit. [6]

Victory Institute (LGBT Leadership Training)
Candidate and Campaign Trainings provide comprehensive, non-partisan training to present and future LGBT candidates, campaign staff and community leaders. Trainees learn necessary skills and strategies by engaging in tough, realistic campaign situations. The Gay & Lesbian Victory Institute is a 501(c)(3) nonprofit. [7]

Running Start - Young Women in Politics
Program includes workshops led by experts in the field on public speaking, networking, fundraising, on-camera media training, and advocacy. Young women candidates and elected officials speak to the girls about what it is like to run as a young woman, how to get involved on a local level, and why they feel it is important to get more women elected. The goal of the program is to encourage the girls to channel their leadership into politics. Running Start is a 501(c)(3) nonprofit. [8

Veterans Campaign

Veterans Campaign's flagship Campaign Training Workshop is a political leadership program for veterans, transitioning service members, and other members of the military community committed to pursuing a "second service" to their country in elected office, political campaigns, advocacy, or civic leadership. Veterans Campaign is a 501(c)(3) nonprofit organization. [9]

Young People For – Fellows Program, Front Line Leaders Academy
Leadership development, fundraising, community-building, campaign organization.
YP4 and FLLA are programs of People For the American Way Foundation, which is a 501(c)(3) nonprofit. [10], [11]