You are wise to be concerned about this issue.  501(c)(3) charities can lose their exempt status for participating in an election of public officials at any level of government. Official statements for or against a candidate are considered participation.

In a Fact Sheet published in 2006, the Internal Revenue Service said that candidate surveys that “focus on a single issue or narrow range of issues, or if the questions are structured to reflect bias” could be considered participation.  The theory behind that statement was that if the readers of the survey were familiar with the positions of the organization, the readers would know which answers were “correct” and to be supported, and which answers were “incorrect” and to be opposed.

In 2007, the IRS issued a formal Revenue Ruling (Rev. Rul. 2007-41) to set forth its guidance.  (See Ready Reference Page: “IRS Guidance Has Not Changed on Electioneering”)  It dropped some of the specific language in the Fact Sheet, but still utilized prior Rev. Rulings as the basis for its position that candidate surveys can be deemed participation if they reflect bias.  It also made clear that the charity is responsible for the content it distributes, even if produced by another organization.  If the material is not even-handed, its distribution can be considered an intervention in the election by the charity.  I would be reluctant to distribute a survey that had been prepared by a partisan organization that did not contain fair summaries of the candidates’ positions.