Why the IRS Must Investigate the Tax-Exempt Syndicate that Weaponized Mamdani’s Campaign

/ 38 minutes of reading

An investigation of a $2+ billion syndicate of tax-exempt organizations raises questions about conversion of charitable donations and government grants into political campaign power through coordinated operations that raise fundamental questions about federal tax law compliance. This investigation builds on our previous reporting that exposed Zohran Mamdani’s elite-funded ‘grassroots revolution,’ but his mayoral victory represents just the visible tip of a much larger operation. Mamdani is merely a product of this syndicate—the coordinated infrastructure that manufactured his political rise operates continuously, creating candidates while maintaining the illusion of grassroots democracy. On paper, these are separate charities and social welfare organizations. In practice, their own filings show shared executives, integrated personnel arrangements, shared office space, and coordinated financial transfers. Professional auditors have flagged “significant deficiencies” in federal fund controls and documented executives holding roles across multiple entities.

Professional auditors at Deloitte and Withum have documented this tax-exempt syndicate of 18+ entities acknowledge “COMMON CONTROL” and “SHARED FACILITIES & EMPLOYEES” with political advocacy groups in their own IRS filings—contradicting the organizational independence required for tax-exempt status. With interlocking management and shared resources across supposedly independent entities, these operational structures raise questions about whether tax-exempt status can be maintained when organizations demonstrate unified control rather than genuine independence.

These patterns warrant comprehensive IRS investigation to determine whether compliance issues with federal tax law exist. Therefore, we have filed a whistleblower complaint with the IRS, providing additional documentation for regulatory review.

The most remarkable aspect of this investigation is that it required no undercover reporting, leaked documents, or whistleblower sources. The organizations documented their own systematic operations in public filings and published communications.

Tax law applies the “substance over form” doctrine (see Revenue Ruling 2007-41, Treasury Regulation 1.501(c)(3)-1), which examines operational reality rather than legal formalities when organizations claim independence while demonstrating unified control. As forensic accountants, we analyze actual operations, financial flows, and control structures rather than relying solely on organizational charts—focusing on how these entities actually function rather than how they appear on paper.

A central question involves the fungibility of cash—money is interchangeable, so even if organizations claim to segregate funds properly, does the influx of millions in government grant money free up other resources for political advocacy? This structure uses multiple tax classifications—501(c)(3) charities, 501(c)(4) social welfare organizations, and PACs—to move money, staff, and resources between “separate” entities that professional auditors have determined operate as unified organizations requiring consolidated financial reporting.

Perhaps most troubling is how large donors receive tax deductions for contributions to 501(c)(3) charities that then transfer millions to their 501(c)(4) political affiliates. When the same individuals control both entities and they share facilities, personnel, and operational resources, this creates a mechanism for tax-deductible political spending—exactly what federal law prohibits.

What oversight mechanisms exist when organizations processing massive revenue streams acknowledge operational unity while maintaining separate legal structures that provide significant tax advantages? This represents approximately $400 million annually in potential tax revenue at stake, with ongoing implications for the integrity of democratic institutions.

The network’s effectiveness is demonstrated through Zohran Mamdani’s mayoral campaign, which shows patterns that warrant examination: over $2 million in elite PAC spending supported his candidacy—exceeding his entire direct campaign fundraising—while organizations claimed independent operations despite coordination patterns that raise mathematical questions.

The system’s sophistication becomes clear when considering that just days after winning the Democratic primary, Mamdani told NBC that ‘I don’t think that we should have billionaires,’ citing wealth concentration as representing ‘so much money in a moment of such inequality.’

When the network can successfully elevate candidates who publicly condemn the very mechanisms that powered their rise, this demonstrates patterns that warrant examination about how authentic-seeming grassroots messaging operates alongside elite infrastructure. The perfect irony: a billionaire-funded network creating anti-billionaire messengers. If the goal is reducing billionaire influence in politics, shouldn’t that include examining the tax mechanisms that enable such influence to operate undetected through systematic coordination disguised as independent grassroots democracy?

Tax-Exempt Syndicate that Weaponized the Mamdani Campaign for NYC Mayor

Note: Readers can click on any images to enlarge them.

Table of Contents

Part I: The Network Entities Mapping the $2+ billion operation: When professional auditors document “common officers” across supposedly independent organizations

Part II: The Systematic Financial Process The four-step conversion: How charitable donations and government grants flow to political operations

Part III: Explicit Admissions in Public Filings The smoking gun: When a $436 million foundation admits “COMMON CONTROL” with political groups in its own IRS filing

Part IV: The Elite Funding Pipeline – Following $693 Million Tracing Soros’s systematic investment: How tax-deductible donations become political spending

Part V: Professional Audit Evidence and Operational Integration When Deloitte identifies “significant deficiency” in tracking $16.2 million in federal funds

Part VI: Government Grant Recipients with Political Operations The taxpayer pipeline: $16.1 million in government grants flowing to organizations with political arms

Part VII: Personnel Overlap and Dual Compensation The revolving door: When the same executives control “separate” charitable and political entities

Part VIII: The “Zero Employee” Operational Structure The impossible organizations: How entities report zero employees while managing hundreds of millions

Part IX: Regulatory Oversight Concerns When the referee plays for the team: Campaign Finance Board personnel with documented network connections

Part X: Investment Income and Scale Considerations The $5.57 billion question: Tax-free investment returns supporting political operations

Part XI: Legal Framework and Precedent Analysis When “substance over form” doctrine meets professional audit evidence

Part XII: Shared Infrastructure and Operational Integration Same address, same personnel, same strategy: The shared command centers across Brooklyn and Manhattan

Part XIII: Enhanced Professional Service Integration The coordination blueprint: Identical policies and shared systems across the network

Part XIV: The Network’s Perfect Deployment – How the $2+ Billion Machine Produced Mamdani’s ‘Revolution” The case study: When elite PAC spending exceeds the candidate’s entire grassroots fundraising

Part I: The Network Entities

This analysis examines patterns across a coordinated network of organizations that professional auditors have determined operate with significant integration despite maintaining separate legal structures. The key entities include:

The $2+ Billion Network Structure

Working Families Party Network
  • Working Families Organization Inc. (501(c)(4)): $48.8 million revenue, reports 0 employees while paying $11.04 million for personnel and administrative costs through shared services
  • WFP National PAC (527): Electoral support operations
  • WFP National Independent Expenditure Committee (Super PAC): Unlimited independent expenditures
Make the Road Network
  • Make the Road New York (501(c)(3)): $31.76 million revenue with $16.1 million in government grants (51% of total revenue)
  • Make the Road Action Inc. (501(c)(4)): Political advocacy arm receiving $165,000+ in transfers from the 501(c)(3)
  • Professional Audit Finding: Withum auditors documented “common officers and board members” across legally separate entities with $165,000+ in related party transactions
Center for Popular Democracy Network
  • Center for Popular Democracy (501(c)(3)): $28.68 million revenue, receives government grants but distributes 259% of grant revenue throughout the network. Enhanced 2023 Soros Network Funding: Received $43,750 directly from Tides Center ($40,000) and Open Society Institute ($3,750), while serving as distribution hub for broader network operations.
  • Center for Popular Democracy Action Fund (501(c)(4)): Political advocacy arm receiving over $1 million in operational support. Enhanced 2023 Soros Network Funding: Received $1.38 million from multiple Open Society entities: $700,000 from Open Society Policy Center (including $500,000 for “nonpartisan civic engagement of communities of color” and $200,000 for debt relief advocacy). Total 2023 CDP Network Soros Funding: $743,750.
  • Operational Integration Evidence: CDP Action Fund explicitly reports that “Center for Popular Democracy (501(c)(3)) serves as the common paymaster for all employees”—the charitable entity literally pays political operatives’ salaries. Both entities operate from shared facilities at 449 Troutman Street, Suite A, Brooklyn, demonstrating complete operational integration despite legal separation.
Tides Network
  • Tides Foundation (501(c)(3)): $350.1 million revenue, $577.4 million in net assets, reports 0 employees
  • Tides Center (501(c)(3)): $233.7 million revenue managing 140 fiscal sponsorship projects
  • Tides Advocacy (501(c)(4)): Political advocacy arm
  • Professional Audit Finding: Deloitte identified “significant deficiency” in federal expenditure controls over $16.2 million, with 290 employees providing services across the network through centralized structure
Open Society Network
  • Open Society Institute (501(c)(3)): $436.3 million revenue, $4.54 billion in net assets
  • Open Society Action Fund Inc. (501(c)(4)): $257 million revenue
  • Fund for Policy Reform Inc. (501(c)(4)): Receives $32.5 million in transfers from Open Society Institute
  • Foundation to Promote Open Society (501(c)(3)): $3.49+ billion in investment assets through sophisticated offshore investment structures (QECL), distributing hundreds of millions globally to organizations engaged in political advocacy and lobbying activities
  • Explicit Admissions: Open Society Institute’s own IRS filings acknowledge “common control,” “shared facilities & employees,” and $36.4 million in political transfers

What questions does this syndicate structure raise when professional auditors determine raise when professional auditors determine that legally separate entities must be treated as unified operations for financial reporting purposes? Under the “substance over form” doctrine, how do these operational realities compare to the legal independence required for tax-exempt status?

Part II: The Systematic Financial Process

The Four-Step Conversion Process

Investigation reveals what appears to be a systematic 4-step process that raises questions about how charitable donations and government grants relate to political campaign support, now documented by independent audits:

Step 1: Initial Funding

Individuals donate to 501(c)(3) charitable organizations, receiving tax deductions for their contributions. Parallel to this, taxpayer money flows into these same charities through government grants totaling over $16 million annually.

Step 2: Transfer of Resources

These 501(c)(3) organizations then provide cash and extensive operational support—including “personnel and administrative services”—to their 501(c)(4) political advocacy affiliates. Professional auditors have verified these transfers exceed $165,000 annually between supposedly independent entities.

Step 3: Political Action

The 501(c)(4)s use these resources for lobbying, political advocacy, and electoral spending, often directing millions to affiliated PACs. Working Families Organization Inc. (501(c)(4)) alone distributed over $2.3 million to PACs in 2023. Simultaneously, these 501(c)(4) entities share resources back with their 501(c)(3) affiliates through cost-sharing agreements, shared personnel arrangements, and operational reimbursements—creating bidirectional resource flows that demonstrate complete operational integration.

Step 4: Policy Feedback Loop

Once elected, candidates supported by this network advance policies and programs that result in more taxpayer funds flowing back to the same 501(c)(3)s—creating what appears to be a self-perpetuating cycle.

How Tax Deductible Contributions Become Political Campaign Power

What questions does this process raise about the fungibility of cash? Even if a 501(c)(3) claims its private donations fund political work, does the presence of millions in government grant money free other funds and operational capacity for politics? Under the “substance over form” doctrine established in Revenue Ruling 2007-41, what matters is operational reality—when the same individuals control financial decisions across supposedly independent entities, do legal separations reflect genuine independence? This forensic accounting approach examines actual control structures and financial flows rather than organizational documents.

Part III: Explicit Admissions in Public Filings

The Blueprint: WFP’s Established Coordination Framework

The Working Families Party’s own documentation reveals their sophisticated understanding of campaign coordination requirements. Their November 9, 2022 post-election analysis “How we helped the Dems defy gravity” provides a detailed roadmap of their operational methods:

The memo describes extensive coordination activities: “WFP coordinated a significant grassroots IE table” (independent expenditures) and explains how they “brought the coalition back together from the primary” to advance endorsed candidates in multiple competitive contests.

The significance for 2025 examination: WFP’s published documentation demonstrates their comprehensive knowledge of coordination disclosure rules and requirements. This expertise makes their subsequent 2025 disclosure patterns warrant examination—they were fully aware of the regulatory framework that raises questions about their compliance.

When organizations maintain claims of independence while operating from shared locations, utilizing common personnel and payroll infrastructure, and executing coordinated financial movements, what differentiates this arrangement from a unified entity deploying multiple legal structures for tactical purposes?

Open Society Institute’s IRS Filing Admissions

Perhaps most revealing, Open Society Institute (501(c)(3))’s own IRS filings document not only transfers TO political entities, but also how those 501(c)(4) political organizations reimburse the 501(c)(3) charity for shared expenses – creating bidirectional resource flows that demonstrate complete operational integration:

Open Society Action Fund Inc. (501(c)(4)): $3,977,407 transfer with Open Society Institute (501(c)(3)) stating “COMMON SOURCE OF FUNDING AND SHARED FACILITIES & EMPLOYEES. Open Society Action Fund Inc. (501(c)(4)) REIMBURSES Open Society Institute (501(c)(3)) FOR ITS ALLOCABLE SHARE OF EXPENSES IN ADVANCE.”

Fund for Policy Reform Inc. (501(c)(4)): $31,719,763 in transfers with Open Society Institute (501(c)(3)) describing “COMMON SOURCE OF FUNDING AND SHARED FACILITIES & EMPLOYEES. Fund for Policy Reform Inc. (501(c)(4)) REIMBURSES Open Society Institute (501(c)(3)) FOR ITS ALLOCABLE SHARE OF EXPENSES IN ADVANCE.”

Fund for Policy Reform (501(c)(4)): $1,000,000 transfer with Open Society Institute (501(c)(3)) noting “ELEMENT OF COMMON CONTROL”

Total Open Society Institute (501(c)(3)) political transfers in 2023: $36,462,230

Center for Popular Democracy’s Operational Integration Evidence

The Center for Popular Democracy network provides additional documentation of operational integration across the Soros funding architecture. While receiving $743,750 from multiple Open Society entities in 2023, the CDP network simultaneously demonstrates the shared infrastructure patterns documented throughout this investigation:

Shared Personnel Systems: Center for Popular Democracy Action Fund (501(c)(4)) explicitly reports that “Center for Popular Democracy (501(c)(3)) serves as the common paymaster for all employees”—the charitable entity literally pays the salaries of political operatives, demonstrating complete operational integration despite legal separation.

Shared Physical Infrastructure: Both Center for Popular Democracy (501(c)(3)) and Center for Popular Democracy Action Fund (501(c)(4)) operate from the same address at 449 Troutman Street, Suite A, Brooklyn—alongside other network entities including Make the Road Action Inc. (501(c)(4)) in Suite C, creating a shared command center for coordinated operations.

Cross-Network Financial Integration: Center for Popular Democracy (501(c)(3)) received $545,202 in government grants in 2023 yet distributed $1,411,940 throughout the network—259% of its government grant revenue. This mathematical impossibility without external coordination demonstrates the cash fungibility principle in operation, where Soros funding enables the distribution of resources far exceeding direct government support.

Direct Political Funding Pipeline: The CDP network serves as both recipient and distributor within the broader architecture, receiving $743,750 from Soros entities while simultaneously transferring $50,000 to Working Families Organization (501(c)(4)) and $474,500 to New York Communities for Change (501(c)(4)), creating documented political funding pipelines.

Combined Self-Documentation Impact: When viewed together, the Working Families Party memo, Open Society Institute IRS filings, and Center for Popular Democracy operational arrangements provide unprecedented direct evidence—organizations explicitly documenting both systematic political campaign intervention and operational control relationships that contradict the independence required for tax-exempt status. The memo’s documentation of “six figure ad buys” alone triggers IRC Section 4955 penalty exposure, while OSI’s admissions of “common control” and CDP’s shared payroll systems support “substance over form” analysis under Revenue Ruling 2007-41.

What questions do these explicit organizational admissions raise about compliance with federal tax law governing tax-exempt organizations? When organizations themselves document these operational relationships and political activities in public filings and published communications, does this eliminate any requirement to establish compliance concerns through inference?

Part IV: The Elite Funding Pipeline – Following $693 Million

The $1.13+ Billion Elite Political Infrastructure

Behind the network’s claimed grassroots authenticity lies what appears to be a sophisticated elite funding operation that raises questions about how billionaire wealth transforms into political influence through multiple coordinated channels:

Open Society Institute Direct Political Infrastructure

Beyond the Tides pipeline, Open Society Institute operates its own massive direct funding apparatus representing one of the largest political philanthropies in the world:

  • Historical Scale: Over $20 billion distributed since 1993 across global operations
  • Current Operations: $436.3 million revenue (2023), $4.54 billion in assets generating substantial tax-free investment income
  • Direct Political Arm: Open Society Policy Center (501(c)(4)) for lobbying Congress on domestic and international policy
  • U.S. Programs Budget: $100+ million annually (18% of total global operations) dedicated to domestic political agenda
  • Transparency Issues: Labeled as “least transparent think tank” by NGO Monitor

Major Direct Political Grantees (2009-2014):

  • Drug Policy Alliance: $62 million
  • American Civil Liberties Union Foundation: $27.7 million
  • Planned Parenthood Federation: $20 million
  • Tides Foundation: $10.1 million (creating the pipeline documented in this analysis)
  • Tides Center: $7.4 million
  • Center for Community Change: $7.2 million
  • Brennan Center for Justice: $7 million

This demonstrates a sophisticated multi-channel approach: OSI funds political operations both directly through its own grantmaking AND indirectly through the Tides pass-through mechanism, maximizing both reach and opacity.

The Foundation to Promote Open Society – The “Mother Ship” Operation

The Foundation to Promote Open Society represents the largest single entity in the network, serving as the primary capitalization source for global political operations:

  • Asset Scale: $3.49 billion in sophisticated investment structures including “INVESTMENT IN QECL” (Qualified Electing Company Limited)—offshore investment vehicles that allow tax deferral on foreign investment income
  • Investment Returns: Over $950 million in annual net investment income from QECL (Qualified Electing Company Limited) and QECF (Qualified Electing Company Fund) structures—offshore investment vehicles that allow U.S. tax-exempt organizations to defer taxation on foreign investment income—generating massive tax-free returns
  • Global Infrastructure: Direct funding of international political operations across continents

Major International Political Infrastructure Funding (2019-2023):

  • Open Society Foundation London: $206.8 million across multiple grants for “programs promoting open, democratic societies”
  • Open Society Foundation Berlin: $12.7 million for political programs across Europe
  • Open Society Initiative West Africa: $19.5 million for “democratic governance” and “active citizenship”

This global scope demonstrates that domestic political operations represent just one component of a worldwide infrastructure funded through U.S. tax-exempt structures.

The $1.13+ Billion Combined Political Infrastructure
The Complete Donor Subsidy Mechanism

The most troubling aspect involves how donor money to 501(c)(3) charities—which generates tax deductions—ultimately subsidizes 501(c)(4) political operations through interlocking relationships:

Soros Network Donations → 501(c)(3) Charities → 501(c)(4) Political Operations:

  • Step 1: Open Society Institute provides massive funding to Tides Foundation (501(c)(3))—$6,922,500 in 2023 alone
  • Step 2: Tides Foundation (501(c)(3)) then transfers $4,555,657 to Working Families Organization Inc. (501(c)(4)) for political operations
  • Step 3: Working Families Organization Inc. (501(c)(4)) distributes $2.3+ million to PACs supporting specific candidates

The Tax Deduction Subsidy: Soros receives charitable tax deductions for donations to Open Society Institute (501(c)(3)), but that money flows through multiple layers to fund political operations that would not qualify for tax deductions if donated directly.

Interlocking Control Relationships Enable the Flow:

Professional auditors have documented systematic control integration that makes the donor subsidy mechanism possible:

  • Unified Executive Control: Theodoro Oshiro serves as Co-Executive Director of Make the Road New York (501(c)(3)) while simultaneously serving as Executive Director of Make the Road Action Inc. (501(c)(4)), receiving $207,989 in combined compensation for controlling both charitable and political operations
  • Shared Financial Management: Center for Popular Democracy Action Fund (501(c)(4)) reports that “Center for Popular Democracy (501(c)(3)) serves as the common paymaster for all employees”—the charity literally pays political operatives’ salaries
  • Shared Facilities and Infrastructure: When Open Society Institute (501(c)(3)) and Open Society Action Fund Inc. (501(c)(4)) operate from the same address (224 West 57th Street), when Center for Popular Democracy (501(c)(3)) and Make the Road Action Inc. (501(c)(4)) share facilities at 449 Troutman Street, and when Working Families Organization Inc. (501(c)(4)) and WFP National PAC (527) coordinate from 77 Sands Street, these arrangements demonstrate operational integration with shared personnel, IT systems, and administrative services.
  • Professional Audit Determination: Both Withum and Deloitte auditors concluded that legally separate entities must be treated as unified operations requiring consolidated financial reporting due to operational integration
  • Explicit IRS Admissions: Open Society Institute’s own Form 990-PF acknowledges “COMMON SOURCE OF FUNDING AND SHARED FACILITIES & EMPLOYEES” with political entities while transferring $36.4 million

This operational unity enables the tax deduction subsidy because the same individuals control financial decisions across the entire pipeline—from initial donations to final political expenditures. (See Part VII for comprehensive personnel analysis and Part XIII for detailed infrastructure evidence.)

This funding pattern demonstrates sophisticated coordination across multiple Soros entities funding the same recipient network, while CDP simultaneously operates as documented in this investigation—receiving government grants, distributing funds throughout the WFP network, and maintaining the shared personnel and facilities that contradict organizational independence.

Beyond Soros – The Broader Donor Subsidy Pattern:

This mechanism isn’t limited to Soros. Any large donor can:

  1. Donate to a 501(c)(3) charity and receive tax deductions
  2. Have that charity transfer operational support to its 501(c)(4) political affiliate
  3. Watch their tax-deductible donation fund political operations

When the same individuals control both the charitable and political entities, the legal separation becomes a fiction that enables tax-deductible political spending—exactly what federal tax law prohibits.

Completing the Circle – Shared Resources Between Final Recipients:

The mechanism becomes even more apparent when examining how the final 501(c)(4) recipients share resources back with their 501(c)(3) affiliates:

  • Make the Road Example: Make the Road Action Inc. (501(c)(4)) receives $165,000 from Make the Road New York (501(c)(3)), but auditors documented $141,274 in outstanding balances flowing back, plus shared executive leadership and $2.4 million in cost-sharing agreements
  • Center for Popular Democracy Example: Center for Popular Democracy Action Fund (501(c)(4)) reports that “Center for Popular Democracy (501(c)(3)) serves as the common paymaster for all employees”—the 501(c)(3) charity literally pays the salaries of political operatives
  • Open Society Example: Open Society Action Fund Inc. (501(c)(4)) explicitly states it “REIMBURSES Open Society Institute (501(c)(3)) FOR ITS ALLOCABLE SHARE OF EXPENSES IN ADVANCE”—showing resources flow both directions between charitable and political operations

This bidirectional flow of resources demonstrates that the charitable and political operations are functionally integrated—donors to the 501(c)(3) are effectively subsidizing political operations, while the 501(c)(4) political entities help fund the charitable operations through shared costs and personnel.

Documenting the Money Flow: From Open Society Institute to Political Power

The Complete Dual-Channel Pipeline

The funding pipeline demonstrates a sophisticated dual-channel grassroots laundering process operating simultaneously through multiple Soros network entities:

Channel 1: Open Society Institute (501(c)(3)) → Tides ($10.52 Million)
  • Tides Foundation (501(c)(3)): $6,922,500 across multiple grants
  • Tides Advocacy (501(c)(4)): $2,050,000 across four separate grants
  • Tides Center (501(c)(3)): $1,550,000 across multiple grants
Channel 2: Open Society Policy Center → Working Families Organization ($5.15 Million Direct)

Beyond the Tides pass-through mechanism, Open Society Policy Center (501(c)(4)) provided massive direct funding to Working Families Organization (501(c)(4)) in 2023:

  • Open Society Policy Center → Working Families Organization: $4,150,000 for “social welfare activities”
  • Open Society Policy Center → Working Families Organization: $1,000,000 for “policy advocacy on access to federal infrastructure funding”
  • Total Direct Network Funding to Working Families Organization: $5,150,000

Mathematical Precision of Grassroots Laundering: The Soros network provides $5.15 million directly plus $4.56 million through Tides (nearly $10 million total), Working Families Organization then distributes $2.3+ million to PACs, with the remainder funding broader network operations that claim grassroots authenticity while serving billionaire political interests.

Seven-Year Systematic Investment Pattern

According to Open Society Foundations’ public grant database, the Soros network provided $7,612,750 in direct grants to core WFP network entities over seven years (2016-2023), with the new 2023 CDP funding revealing the accelerating scale:

Center for Popular Democracy Network: $3,473,750 Total (2021-2023)

  • 2023 Funding: $743,750 (as detailed above)
  • Center for Popular Democracy Action Fund (501(c)(4)): $1,715,000 for political advocacy operations (2021-2022)
  • Center for Popular Democracy (501(c)(3)): $1,015,000 for organizing programs (2021-2022)

Make the Road Network: $4,139,000 (2016-2023)

  • Make the Road Action Inc. (501(c)(4)): $1,950,000 for political operations
  • Make the Road New York (501(c)(3)): $2,165,000
Step 2: Dual-Channel Convergence → Working Families Party Network ($10.89 Million Total)

Both channels converge on Working Families Organization, demonstrating systematic coordination:

Indirect Channel – Tides Foundation (501(c)(3)) Grants:

  • Working Families Organization Inc. (501(c)(4)): $4,555,657
  • Center for Popular Democracy (501(c)(3)): $560,000
  • Make the Road Action Inc. (501(c)(4)): $75,000
  • Make the Road New York (501(c)(3)): $40,000

Tides Advocacy (501(c)(4)) Political Operations Funding:

  • Working Families Organization Inc. (501(c)(4)): $295,173
  • WFP National PAC (527): $135,000
  • Make the Road Action Inc. (501(c)(4)): $45,000

Direct Channel – Open Society Policy Center (501(c)(4)) Funding:

  • Working Families Organization Inc. (501(c)(4)): $5,150,000 (as detailed above)

Combined Total to Working Families Organization: $9,705,657 from dual channels

Step 3: Working Families Organization Inc. (501(c)(4)) → PACs

After receiving nearly $10 million from dual Soros network channels ($5.15 million direct + $4.56 million through Tides), Working Families Organization Inc. (501(c)(4)) converts these funds into direct political power:

Working Families Organization Inc. (501(c)(4)) → PAC Distributions:

  • WF Party Building Account (PAC): $2,200,000 (2023)
  • WFP National Independent Expenditure Committee (Super PAC): $13,000 (2023)
  • MoveOn.org Political Action-Super PAC: $10,000 (2023)
  • Total Direct Political Conversion: $2,223,000

Part V: Professional Audit Evidence and Operational Integration

Independent Auditor Validation

Independent professional auditors at two major accounting firms have documented systematic control deficiencies and operational integration that raise questions about organizational independence.

Deloitte Finding 2023-001: Significant Deficiency

Deloitte’s audit of Tides Organizations identified “a control gap” where “not all program expenditures were reported in the correct year,” demonstrating inadequate controls over $16.2 million in federal expenditures across organizations that simultaneously transfer millions to political entities. Professional finding: 290 employees providing services across the network through centralized structure.

What questions does this “significant deficiency” in federal fund controls raise when these same organizations are transferring millions to political operations?

Withum Control Deficiency Documentation

Withum’s audit of Make the Road Network revealed systematic control challenges in maintaining organizational independence, documenting “common officers and board members” across legally separate entities with outstanding cross-balances of $251,274 and cost-sharing agreements totaling $2.4 million. Related party transactions exceeded $165,000 between 501(c)(3) and 501(c)(4) entities.

Professional Validation of “Substance Over Form” Analysis

Both Withum and Deloitte auditors recognized operational integration by treating legally separate entities as unified operations requiring consolidated financial reporting. This professional determination directly supports “substance over form” analysis under Revenue Ruling 2007-41—when independent auditors conclude that separate legal entities must be treated as unified operations for financial reporting purposes, what questions does this raise about examining operational reality rather than legal formalities for tax purposes? This forensic accounting methodology focuses on actual operational control and financial integration rather than formal organizational structures.

Part VI: Government Grant Recipients with Political Operations

The Taxpayer Funding Pipeline

Make the Road New York (501(c)(3)) – $16.1 Million in Government Funding

Major NYC Department Grants (2023):

  • NYC Department of Social Services: $8,432,600 (Immigration and human services)
  • NYC Administration for Children’s Services: $2,851,442 (Child welfare and family services)
  • NYC Department of Youth & Community Development: $1,644,516 (Youth programs and community development)
  • NYC Department of Health & Mental Hygiene: $1,089,654 (Health access services)

Federal Government Grants:

  • US Department of Health & Human Services: $1,388,095 (Federal health and human services programs)
  • Additional federal programs: Including Community Services Block Grant, Medical Assistance Program, Adult Education, and other federal initiatives

State and Local Grants:

  • Additional federal and state grants: $694,323 (Various programs including education and workforce development)

TOTAL GOVERNMENT FUNDING: $16,124,582 (representing 51% of total organizational revenue)

Simultaneous 501(c)(3) to 501(c)(4) Political Transfers – AUDITOR VERIFIED:

  • $165,000 to Make the Road Action Inc. (501(c)(4)) for “Workplace Justice”
  • $93,000 to NY Communities (501(c)(4)) for “Workplace Justice”

Grant Distribution Network: Make the Road New York (501(c)(3)) distributed $2,468,291 to 29 organizations, creating circular funding relationships throughout the network. This includes distributing funds to organizations that simultaneously fund other network entities, demonstrating the interconnected nature of the financial flows.

Circular Funding Documentation: Make the Road New York (501(c)(3)) receives $440,748 from Center for Popular Democracy (501(c)(3)) while simultaneously distributing $2.47 million to other network entities, creating documented circular funding relationships that demonstrate operational integration across supposedly independent organizations.

What oversight mechanisms exist when an organization receiving over $16 million in taxpayer funds simultaneously transfers resources to political advocacy arms?

Center for Popular Democracy (501(c)(3)) Distribution Pattern

Center for Popular Democracy (501(c)(3)) provides a perfect example of the cash fungibility principle in operation. The organization received $545,202 in government grants but distributed $1,411,940 throughout the network—259% of its government grant revenue—with the excess funded through other network sources, demonstrating sophisticated financial integration across supposedly independent entities.

Documented Circular Funding Relationships:

  • Center for Popular Democracy (501(c)(3)) → Make the Road New York (501(c)(4)): $440,748 (creating direct circular funding between network entities)
  • Center for Popular Democracy (501(c)(3)) → New York Communities for Change (501(c)(4)): $474,500 (network expansion funding)
  • Center for Popular Democracy → (501(c)(3)) Working Families Organization Inc. (501(c)(4)): $50,000 (direct political advocacy funding)

Mathematical Analysis: When a government-funded 501(c)(3) distributes 259% of its grant revenue, the excess funding must come from other network sources. This demonstrates the cash fungibility principle—taxpayer money frees up other resources for political operations through systematic cross-funding between “independent” entities.

Specific Government Grant Programs Include:

  • Community Services Block Grant programs
  • Federal health and human services initiatives
  • Adult education and workforce development funding
  • Medical Assistance Program components
  • Various state and local education grants
Tides Network Federal Expenditures

Professional audits document $16.2 million in federal expenditures across multiple federal programs, including:

  • Department of Health and Human Services grants
  • Department of Education funding
  • Environmental and social justice program grants
  • Community development block grants

What oversight mechanisms exist when organizations processing these substantial federal expenditures simultaneously maintain the control deficiencies identified by professional auditors?

Part VII: Personnel Overlap and Dual Compensation

The Revolving Door: Unified Control Across Entity Types

Cross-Network Executive Integration – AUDITOR VERIFIED

Theodoro Oshiro – Unified Control:

  • Make the Road New York (501(c)(3)): $199,370 as Co-Executive Director
  • Make the Road Action Inc. (501(c)(4)): $8,619 as Executive Director
  • Total Annual Compensation: $207,989 across supposedly independent entities

Daniel Altschuler – Political Control:

  • Make the Road New York (501(c)(3)): $158,352 as “Director of Politics”
  • Make the Road Action Inc. (501(c)(4)): $42,704 as Co-Executive Director
  • Total Annual Compensation: $201,056

What questions does the existence of a “Director of Politics” position within a 501(c)(3) charitable organization legally prohibited from political campaign intervention raise about functional integration of charitable and political operations?

Leonard Benardo (Open Society Network):

  • Open Society Institute (501(c)(3)): $936,086
  • Alliance for Open Society International Inc. (501(c)(3)): $794,480
  • Total Annual Compensation: $1,730,566

Mark Malloch-Brown (Former President Open Society Network):

  • Open Society Institute (501(c)(3)): $595,701
  • Alliance for Open Society International Inc. (501(c)(3)): $1,165,109
  • Total Annual Compensation: $1,760,810

Tascha Van Auken – Revolving Door Evidence:

  • 2022-2023: NY WFP Deputy Campaigns Director (political party operations)
  • 2025: Field Director for WFP-endorsed Mamdani campaign
  • Campaign Payments: $79,285 in documented payments from Mamdani campaign
  • Control Evidence: Direct pipeline from WFP political operations to campaign management for WFP-endorsed candidates

What questions does this systematic movement of personnel between charitable organizations, political advocacy arms, political parties, and campaigns raise about operational unity disguised through legal separation? From a “substance over form” perspective established in Revenue Ruling 2007-41, when the same individuals make strategic decisions across the entire pipeline, do legal distinctions reflect operational reality? Forensic accounting analysis examines these actual control relationships and decision-making authority rather than formal organizational charts.

IRC Section 4958 addresses excess compensation from tax-exempt organizations. What oversight exists when executives receive compensation packages exceeding $1.7 million across supposedly independent entities?

Part VIII: The “Zero Employee” Operational Structure

The Organizational Fiction

Several organizations processing massive revenue streams report zero employees on their Form 990 filings as part of disclosed shared services arrangements:

Evidence from Independent Audits:
  • Tides Foundation (501(c)(3)): $350.1 million revenue, 0 employees reported per disclosed shared services model, with services provided by Tides Network employing 290 people
  • Open Society Action Fund Inc. (501(c)(4)): $257 million revenue, 0 employees reported per disclosed arrangement, paid $2,735,107 for personnel services with written resource sharing arrangement
  • Working Families Organization Inc. (501(c)(4)): $48.8 million revenue, 0 employees reported per disclosed arrangement, paid $11.04 million for personnel and administrative costs

Professional auditors documented this arrangement and determined it requires consolidated financial reporting due to operational integration. What questions does such a structure raise about whether organizational independence required for tax-exempt status is maintained? When professional auditors determine that “zero employee” entities must be consolidated due to operational unity, does this support “substance over form” analysis under Revenue Ruling 2007-41 that looks beyond legal structures to actual operations? This forensic accounting approach examines actual operational control and resource sharing rather than formal employment structures.

Part IX: Regulatory Oversight Concerns

When the Referees Play for the Team

Campaign Finance Board Personnel Questions

Larry Moskowitz – CFB Board Member:

  • Sits on NYC Campaign Finance Board’s governing body
  • Founding WFP staff member for over 15 years
  • Had decision-making authority during coordination period

David Duhalde – CFB Senior Staff:

  • CFB Senior Candidate Services Liaison with access to sensitive information
  • Publicly declared himself “lead DSA member going all in on electing Mamdani”
  • Had access during coordination activities

Timeline: Four same-day circular transactions totaling $50,697.14 occurred while CFB had a 15-year WFP veteran on its governing board and a self-described partisan advocate in senior staff position.

What questions does this raise about the integrity of oversight when regulators have documented connections to the entities they’re supposed to monitor?

Part X: Investment Income and Scale Considerations

The Scale of Tax-Free Wealth

Total Network Operations: $2+ billion annually (auditor-verified)

Investment Income Considerations:
  • Total Network Assets: $5.57+ billion generating tax-free investment income
  • Foundation to Promote Open Society (501(c)(3)): $3.49 billion in sophisticated investment assets including offshore QECL (Qualified Electing Company Limited) structures—investment vehicles that allow tax deferral on foreign investment income—generating over $950 million in annual net investment income through tax-exempt investment vehicles
  • Open Society Institute (501(c)(3)): $4.54 billion in net assets (separate from $436.3 million annual revenue)
  • Tides Foundation (501(c)(3)): $577.5 million in net assets (Deloitte verified)
  • Conservative 3% annual return: $260+ million in untaxed investment income annually

This scale of tax-free investment income generation—equivalent to a Fortune 500 corporation’s assets—raises questions about tax treatment when these assets support organizations acknowledging “common control” with political entities. The sophisticated wealth management demonstrates institutional-scale operations: Foundation to Promote Open Society (501(c)(3)) utilizes complex offshore investment structures (QECL – Qualified Electing Company Limited) generating over $950 million in annual net investment income, while Open Society Institute (501(c)(3)) holds $4.54 billion in additional assets, all generating tax-free returns that would otherwise be subject to corporate taxation.

What questions does this scale of sophisticated offshore tax-exempt investment income generation raise when these assets support organizations that acknowledge “common control” with political entities?

Part XI: Legal Framework and Precedent Analysis

Legal Standards and Regulatory Framework

“Substance Over Form” Doctrine Application

The IRS applies the “substance over form” doctrine to evaluate whether organizational structures reflect operational reality. Professional auditors at both Deloitte and Withum provided validation by treating legally separate entities as unified operations requiring consolidated financial reporting.

Questions for Regulatory Examination: When independent professional auditors determine that legally separate entities must be treated as unified operations for financial reporting purposes, what questions does this raise about examining operational reality rather than legal formalities for tax purposes?

Treasury Regulation Applications

Treasury Regulation 1.501(c)(3)-1(c)(3)(i): Establishes absolute prohibition on political campaign intervention by 501(c)(3) organizations. Questions raised: What regulatory examination is warranted when professional audit evidence documents direct control over political entities AND when organizations publish documentation of systematic political campaign intervention across multiple federal races?

Treasury Regulation 1.4958-1(b): Requires that all compensation from related organizations be considered in reasonableness determination. Questions raised: What oversight mechanisms exist for auditor-verified dual compensation arrangements exceeding $1.7 million per executive?

Treasury Regulation 1.6033-2(a)(2)(ii)(f): Requires disclosure of relationships with other organizations. Questions raised: What compliance concerns arise when “zero employee” arrangements are contradicted by professional audits showing 290+ employees across shared services?

Government Auditing Standards

Organizations receiving federal funds must maintain adequate controls over federal expenditures. Questions raised: What regulatory examination is warranted when Deloitte’s “significant deficiency” Finding 2023-001 identifies systematic control gaps in tracking $16.2 million in federal expenditures across organizations that simultaneously transfer millions to political entities?

Regulatory Compliance Patterns That Warrant Examination

The combination of professional audit evidence, explicit organizational admissions in IRS filings, and mathematical coordination patterns creates an unprecedented framework for regulatory examination. These patterns raise fundamental questions about:

  • Whether operational unity documented by independent auditors contradicts the organizational independence required for tax-exempt status
  • How cash fungibility principles apply when government grants enable political activities through sophisticated financial engineering
  • Whether “substance over form” analysis should examine actual control structures and financial flows rather than formal organizational documents
  • What oversight mechanisms exist when organizations processing approximately $685,000 in daily tax revenue acknowledge operational unity while maintaining separate legal structures

These questions remain within the purview of appropriate regulatory authorities to investigate and address through established examination processes.

Part XII: Shared Infrastructure and Operational Integration

Same Address, Same Strategy: The Command Centers

Physical Address Coordination Evidence

Brooklyn Command Centers – 449 Troutman Street:

Manhattan/Brooklyn Operations – 77 Sands Street, Brooklyn, 6th Floor:

San Francisco Network Hub – 1012 Torney Avenue:

Manhattan Headquarters – 224 West 57th Street, New York:

 

Shared Addresses and Operational Integration Between 501c3 and 501c4 Entities

Operational Integration Beyond Address Sharing

Shared Personnel Control Systems:

  • Center for Popular Democracy Action Fund (501(c)(4)): “Center for Popular Democracy (501(c)(3)) serves as the common paymaster for all employees”
  • Make the Road entities: $2.4 million in cost-sharing agreements for personnel services
  • Working Families Organization Inc. (501(c)(4)): $11.04 million for personnel and administrative costs through shared services arrangements

Integrated Financial Management:

  • Cross-entity outstanding balances ($251,274 between Make the Road entities)
  • Shared accounting and bookkeeping systems evidenced by professional audit findings
  • Systematic fund transfers requiring coordinated financial planning

What questions do these shared operational systems raise about the organizational independence required for tax-exempt status? When organizations share physical space, personnel systems, financial management, and strategic decision-making while claiming legal independence, what examination is warranted under the “substance over form” doctrine established in Revenue Ruling 2007-41?

The systematic nature of these operational arrangements, combined with professional audit evidence of unified control, raises questions about whether legal separations reflect genuine independence or represent operational unity disguised through legal formalities maintained for regulatory advantage.

Part XIII: Enhanced Professional Service Integration

The Coordination Blueprint: Questions About Operational Independence

Cross-Network Professional Coordination

Open Society Institute (501(c)(3)) Professional Infrastructure:

  • 110+ professional service providers over $50,000
  • 407 employees paid over $50,000
  • Major services: Legal ($1.1M), IT Support ($3.6M), Facilities ($1.2M)

Tides Network Professional Services:

  • 27 independent contractors over $100,000
  • 290 employees across network providing centralized services
  • Shared professional infrastructure managing $350+ million

Coordinated Administrative Integration:

  • Identical conflict of interest policy language across entities
  • Coordinated Form 990 preparation and review processes
  • Shared administrative systems and procedures
Questions About Compliance and Independence

What questions does this level of administrative coordination raise about operational independence? When organizations maintain identical policies, coordinated filing processes, and shared professional service infrastructure, what examination is warranted regarding whether organizational independence required for tax-exempt status is maintained?

The systematic nature of professional service coordination across entities processing over $2 billion annually suggests operational unity that may warrant regulatory examination under the “substance over form” doctrine. When professional auditors determine that legally separate entities must be consolidated due to operational integration, what questions does this raise about tax compliance when the same operational reality governs tax-exempt status determinations?

Patterns That Warrant Regulatory Review

The combination of shared professional services, coordinated administrative systems, and identical operational procedures across legally separate entities creates patterns that raise questions about:

  • Whether administrative coordination contradicts the independence required for separate tax-exempt status
  • How shared professional infrastructure affects the evaluation of organizational independence
  • What oversight mechanisms exist when coordinated administrative systems span organizations claiming separate legal status

These operational coordination patterns, when combined with professional audit evidence of unified control, present questions that remain within the purview of appropriate regulatory authorities to examine through established compliance review processes.

Part XIV: The Network’s Perfect Deployment – How the $2+ Billion Machine Produced Mamdani’s “Revolution”

The Network’s Effectiveness in Action

The network’s effectiveness reaches its ultimate demonstration through Zohran Mamdani’s mayoral campaign, where the $2+ billion coordinated infrastructure successfully manufactured a “grassroots revolution” powered by the very elite mechanisms the candidate publicly condemned. Despite building his political brand around rejecting elite influence and championing authentic working-class politics, the coordinated system converted over $2 million in elite PAC support directly connected to the billionaire pipeline documented in this investigation—spending more than his entire direct campaign raised from actual voters. This represents the machine’s most sophisticated achievement: creating the perfect anti-elite messenger through elite infrastructure.

The cycle demonstrates the system’s ultimate capability: when taxpayer-funded “charitable” organizations coordinate political support for candidates who publicly condemn elite influence, while those same candidates advocate for increased government funding to the organizations that elected them, the network achieves complete operational success. The mathematical precision of coordination, combined with the candidate’s post-victory condemnation of the very wealth concentration that powered his rise, reveals a system capable of manufacturing authentic-seeming grassroots movements while maintaining complete operational control through the mechanisms documented throughout this investigation.

Proof of the Machine’s Capabilities

Two supposedly “independent” PACs spent $2,022,238 supporting Mamdani—more than his entire direct campaign fundraising of $1,708,494. This demonstrates the network’s sophisticated capability to manufacture grassroots authenticity while operating through elite infrastructure, executing the systematic approach the Working Families Party explicitly documented in their memo detailing “400,000 doors knocked,” “six figure ad buys,” and coordinated field operations across multiple states.

WFP National PAC (527): $701,792 total operation

  • $60,955 directly supporting Mamdani
  • $539,616 attacking Andrew Cuomo (only major candidate not WFP-endorsed)
  • Led by Joe Dinkin (National WFP Deputy Director) and Mike Boland (WFP Chief of Staff)

New Yorkers for Lower Costs PAC: $1,320,446 total operation

  • $893,877 supporting Mamdani with positive messaging
  • $424,069 in additional opposition research against Cuomo
  • 71.5% funding from out-of-state tech billionaires
The Complete Elite Funding Pipeline Deployment

Step 1: Open Society Institute → Tides Foundation → Working Families Organization

  • Open Society Institute provides $6,922,500 to Tides Foundation (501(c)(3))
  • Tides transfers $4,555,657 to Working Families Organization (501(c)(4))
  • Working Families Organization (501(c)(4)) distributes $2,200,000 to WF Party Building Account (PAC)

Step 2: Working Families Organization → WFP National PAC

  • Working Families Party PAC (501(c)(4)) contributes $100,000 to WFP National PAC (501(c)(4))
  • WFP National PAC spends $60,955 directly supporting Mamdani
  • Same PAC spends $539,616 attacking Cuomo

Step 3: Elite Donors → New Yorkers for Lower Costs PAC → Mamdani

The Government Grant Pipeline Supporting the Network’s Success

NYC Taxpayers → Make the Road NY → Political Operations → Network Victory

  • NYC taxpayers fund Make the Road NY (501(c)(3)): $16.1 million in 2023
  • Make the Road NY transfers to Make the Road Action (501(c)(4)): $165,000
  • Make the Road Action coordinates with WFP entities supporting Mamdani
The Smoking Gun Coordination Evidence
  • June 11, 2025: Make the Road Action (501(c)(4)) contributes exactly $45,697.14 to WFP National PAC (501(c)(4))
  • Same day: WFP National PAC reports identical $45,697.14 expenditure back to Make the Road Action for “Phone Bank”
  • Mathematical impossibility without advance coordination demonstrates unified operational control
The Taxpayer Matching Fund Amplification Strategy

Beyond the direct elite funding, the coordinated network generated additional taxpayer subsidies through NYC’s public campaign finance system, demonstrating sophisticated understanding of regulatory mechanisms:

“Mutual Aid” Coordination Generating Public Funds:

  • March 24, 2025: Mamdani announced reaching “maximum funding limit”
  • May 18, 2025: Mamdani video telling supporters to donate to Adams because candidates are “running together to defeat Andrew Cuomo”
  • Result: Adams receives $117,000 over two days
  • Taxpayer Impact: $14,300 in public matching funds generated through coordinated effort (8-to-1 matching ratio)
The Policy Feedback Loop: Completing the Cycle

The network achieves its ultimate success through a self-perpetuating cycle that demonstrates the system’s sophisticated design. When elected officials support the programs that funded their rise, the machine achieves complete operational success:

Make the Road New York (501(c)(3)) Success Model:

  • Receives $16.1 million in government grants (51% of total revenue)
  • Transfers $165,000 to political advocacy arm (Make the Road Action (501(c)(4))
  • Coordinates support for candidates who advocate for increased social program funding
  • Elected candidates support expanded funding to organizations like Make the Road
Mathematical Precision Demonstrates Systematic Coordination

The network’s operational unity becomes undeniable through documented circular transactions totaling $50,697.14 across multiple “independent” organizations:

American-Arab Anti Discrimination Committee & New Yorkers for Lower Costs PAC:

Make the Road Action & WFP National PAC:

 

Mathematical Precision of Coordination

The Network’s Perfect Success Story

The network’s effectiveness is demonstrated through its ability to successfully elevate candidates who publicly condemn the very mechanisms that powered their rise. When the machine can create anti-billionaire messengers through billionaire infrastructure while maintaining the appearance of grassroots authenticity, this reveals a system operating at peak sophistication. The mathematical precision of coordination, combined with systematic policy feedback loops, demonstrates a $2+ billion political machine capable of manufacturing authentic-seeming democratic movements while maintaining complete operational control through the tax-exempt mechanisms documented throughout this investigation.

Conclusion

Through explicit admissions in their own IRS filings, professional audit evidence, and mathematical coordination patterns, this $2+ billion syndicate has documented its own systematic operations that raise fundamental questions about the boundaries between charity and politics in America. When organizations acknowledge “common control” with political entities while claiming tax-exempt status, when professional auditors identify control deficiencies in federal fund tracking, and when penny-perfect circular transactions occur between “independent” entities, these patterns reveal a sophisticated political machine operating under the guise of charitable work.

The network’s effectiveness demonstrates remarkable sophistication in manufacturing authentic-seeming grassroots movements while maintaining complete operational control through tax-exempt mechanisms. Mamdani represents not an anomaly, but the system working exactly as designed—a product manufactured by a $2+ billion political machine that specializes in creating candidates who publicly condemn the very mechanisms that created them. Open Society Institute’s IRS filing admissions of “common control” and $36.4 million in political transfers provide definitive evidence of operational unity, while professional audit findings from Deloitte and Withum validate concerns about organizational independence. Combined with mathematical coordination evidence, this represents unprecedented direct documentation of systematic operations that warrant comprehensive regulatory response.

The documentation reveals an even more sophisticated funding architecture than initially documented. The Soros network’s $7.61 million systematic investment over seven years (2016-2023) in core WFP network entities—including $743,750 in 2023 Center for Popular Democracy funding alone—demonstrates the true scale of elite coordination disguised as grassroots democracy. When the same network simultaneously receives over $16 million in government grants while maintaining shared personnel systems, identical office addresses, and coordinated financial transfers, this creates a mechanism where both taxpayer funds and billionaire wealth converge to manufacture political movements that claim authentic working-class origins.

The application of forensic accounting principles—particularly the “substance over form” doctrine established in Revenue Ruling 2007-41—reveals that when organizations share executives, integrated personnel arrangements, office space, and engage in coordinated financial transfers, legal separations become fictions maintained only for regulatory advantage. The cash fungibility principle demonstrates how government grants enable political activities by freeing up organizational resources, creating a mechanism where taxpayer funds indirectly subsidize elite political operations through sophisticated financial engineering. The Center for Popular Democracy’s distribution of 259% of its government grant revenue throughout the network exemplifies this principle—mathematical evidence that external coordination enables resource flows far exceeding direct government support.

Perhaps most remarkable is the network’s capability to successfully elevate candidates who publicly condemn the very mechanisms that powered their rise. When a billionaire-funded infrastructure can create anti-billionaire messengers while maintaining the appearance of grassroots authenticity, this reveals a system operating at peak sophistication. The mathematical precision of coordination, combined with systematic policy feedback loops, demonstrates a political machine capable of manufacturing democratic legitimacy while obscuring its own elite foundations. The financial documentation—from OSI’s explicit “common control” admissions to CDP’s shared payroll systems—provides unprecedented direct evidence of this systematic deception.

What oversight mechanisms exist when organizations processing approximately $685,000 in daily tax revenue acknowledge operational unity while maintaining separate legal structures that provide significant tax advantages? When professional auditors determine that legally separate entities must be treated as unified operations for financial reporting purposes, what questions does this raise about examining operational reality rather than legal formalities for tax purposes? When the same funding architecture that processes $7.61 million in systematic elite investments simultaneously receives taxpayer grants and claims grassroots authenticity, what distinguishes this from sophisticated money laundering designed to obscure the true sources of political power? These questions remain within the purview of appropriate regulatory authorities to investigate and address.

The systematic patterns documented in this investigation were serious enough to warrant formal IRS whistleblower complaints providing additional documentation for regulatory review. The most remarkable aspect of this investigation is that it required no undercover reporting, leaked documents, or whistleblower sources—the organizations documented their own systematic operations in public filings and published communications. The financial evidence strengthens this documentation: when organizations explicitly report shared payroll systems across charitable and political entities, when they acknowledge “common control” in federal filings, and when they distribute resources at mathematical ratios impossible without external coordination, the evidence speaks for itself.

The integrity of the tax-exempt system and public confidence in democratic institutions requires immediate examination of these patterns by appropriate regulatory authorities. When organizations confess unified control in their own tax filings while claiming independence, when professional auditors document operational integration, and when mathematically impossible coordination occurs, the evidence speaks for itself. The documentation of $7.61 million in systematic elite funding combined with over $16 million in government grants flowing through shared operational infrastructure demonstrates a scale of coordination that transcends individual campaign violations—this represents systematic capture of democratic institutions through sophisticated financial engineering designed to manufacture grassroots legitimacy while concealing elite control.

This analysis examines over 20,000 pages of publicly available documents including IRS filings, professional audits, and campaign finance records. The mathematical precision of coordination patterns, combined with professional auditors’ findings and financial documentation totaling over $7.61 million in systematic funding relationships, raises questions for appropriate regulatory authorities to investigate.

PUBLIC RECORD DISCLAIMER: This analysis is based exclusively on publicly available records. No confidential or non-public information has been used. This represents investigative examination of patterns observable in public records and raises questions for regulatory consideration rather than making legal determinations.

For daily updates, follow @SamAntar on X (formerly Twitter)

Written by Sam Antar | Forensic Accountant & Fraud Investigator

© 2025 Sam Antar. All rights reserved.

 

Related Posts

Scroll to Top