Two foundations that are legally barred from partisan politics are working with an arm of the Republican National Committee to arrange more than 100 campus rallies and a possible Rose Garden ceremony on the first anniversary of the U.S. invasion of Grenada.

The Oct. 24-25 activities, which will feature some of the American students who were on Grenada during the invasion, are likely to highlight the theme of U.S. military resurgence that President Reagan has used throughout the campaign.

The events are being coordinated in part by the USA Foundation, a nonpartisan, tax-exempt group founded last year. The foundation's chairman and co-founder, Jack Abramoff, also heads the College Republican National Committee, the youth affiliate of the Republican National Committee.

Abramoff maintains that the USA Foundation's role in what is billed as "Student Liberation Day" is nonpartisan.

In a Sept. 12 letter to Republican campus leaders, however, he cited the benefits to Reagan's campaign.

The letter, written on the College Republicans' stationery, says: "While the Student Liberation Day Coalition is nonpartisan and intended only for educational purposes, I don't need to tell you how important this project is to our efforts as CRs College Republicans . I am confident that an impartial study of the contrasts between the Carter/Mondale failure in Iran and the Reagan victory in Grenada will be most enlightening to voters 12 days before the general election."

The letter also says that the College Republicans are "working with the USA Foundation to bring those rescued students" to the campuses.

The second group coordinating the Grenada activities -- which will include a three-hour documentary to be aired on the Chamber of Commerce satellite network -- is the newly formed American Opportunity Foundation. The tax-exempt group's founder and chairman is Rep. Newt Gingrich (R-Ga.).

The tax code says that such tax-exempt groups cannot "participate or intervene" in "any political campaign."

The activities, which coincide with a volume of Grenadan documents soon to be published by the State and Defense departments, raise questions about the degree of coordination between Republican officials and groups that are supposed to be nonpartisan.

Abramoff said in an interview that the USA Foundation is sponsoring the Grenada activities to encourage debate. "It's not really a partisan thing or a campaign thing," he said. "We don't do stuff to promote the Republican cause in any way."

The foundation plans to fly 100 or more American students who had been on Grenada to rallies at "targeted" campuses around the country.

Abramoff said his group got a list of the students "through some channels at the White House."

The foundation says there are tentative plans for the students to appear with Reagan at a Rose Garden ceremony and White House luncheon on Oct. 24, although a White House spokesman said no such events are now scheduled.

Abramoff said he and other College Republicans started the USA Foundation, which distributes a news service and radio programs to college campuses.

Jeff Pandin, who works for both groups, said that Abramoff "wears two hats. When he has his College Republican hat on, he's partisan. When he has his USA hat on, he's nonpartisan."

The USA Foundation has received $250,000 this year from corporations, individuals and such conservative groups as the Adolph Coors Foundation.

The College Republicans receive $120,000 of their $660,000 budget from the RNC.

Abramoff said the Young College Democrats were invited to join the Grenada activities, but a spokesman for the group denied this.

Gingrich's American Opportunity Foundation has produced an ad that pictures blindfolded American hostages in Iran and an American student from Grenada kissing U.S. soil last year. "On Oct. 25, 1984," it says, "America will debate the difference between bondage and freedom."

Gingrich said the events would be "a nonprofit, educational experience." He said that each selected campus would "invite . . . liberal Democrats to come and explain why they thought Iran was a more appropriate model than Grenada."

"If it does help the president's campaign, it does," said foundation director Maura Gavigan.

Another sponsor, Rep. Duncan L. Hunter (R-Calif.), said he welcomed the debates because "when you have students kissing the ground and saying 'God bless Ronald Reagan,' you can let the opposition have their say."

Partisan activities by tax-exempt groups also became an issue last spring, when another College Republican leader and Reagan-Bush campaign officials asked several conservative student groups to join a proposed youth rally for Reagan at the Republican National Convention in Dallas. The Aug. 21 rally was never held.

A memo passed out to the "August 21 Coalition" at Reagan-Bush headquarters in late March said the rally would counter left-wing student protests planned for Dallas.

"The news coverage of this event could not be bought at any price," the memo said. "The average voter turns on the television and sees young people waving the flag, tears streaming down their cheeks while they sing 'God Bless America' and chanting 'Four More Years in '84.' The effect is dazzling."

Ralph Reed, then executive director of the College Republicans, said:

"To tell the truth, I wanted to do a pro-Reagan rally but couldn't, because it would violate the tax-exempt status of the groups. I thought something like a 'God Bless America' rally would be a proper vehicle. It would advocate support for President Reagan, but wouldn't talk about his reelection at all."

But some student leaders objected. Steve Baldwin, head of the nonpartisan Students for a Better America, said the Reagan campaign's youth director, Liz Pickens, suggested at the meeting that the groups pay for the student demonstrators to travel to Dallas. "A lot of us thought it was dumb," he said. "We couldn't get our organizations involved legally."

Reagan campaign spokesman John Buckley said that there had been some discussion about the student groups paying their way to the rally, but that he believes that tax-exempt groups are not prohibited from paying such expenses.