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

Updated September 2, 2025 to improve sourcing accuracy and attribution of professional audit findings

An investigation of 20+ tax-exempt organizations controlling over $2 billion in assets reveals financial flows and operational relationships documented in public filings that raise 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 outcome of a much larger operational structure. The infrastructure that supported Mamdani’s political rise—documented through public filings showing shared executives, financial transfers, and operational relationships—continues operating across multiple campaigns while maintaining the appearance of independent grassroots organizations.

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 identified “significant deficiencies” in federal fund controls and documented executives holding roles across multiple entities.

Professional audits by Deloitte and Withum document operational integration requiring consolidated financial reporting for some entities. Meanwhile, organizations’ own IRS filings show varying disclosure practices: some entities provide comprehensive Schedule R disclosures of their operational relationships with political advocacy groups, acknowledging “COMMON CONTROL” and “SHARED FACILITIES & EMPLOYEES,” while others systematically omit similar relationship disclosures despite documented shared leadership and financial flows. This selective disclosure pattern raises questions about compliance with federal reporting requirements.

These documented 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 investigation required no undercover reporting, leaked documents, or whistleblower sources. The organizations documented their operational relationships 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 evaluating tax-exempt status. This analysis examines actual operations, financial flows, and control structures documented in public filings—focusing on how these entities function in practice rather than their formal organizational structure.

A key question involves cash fungibility—when organizations claim to segregate funds properly, does the influx of millions in government grant money free up other resources for political advocacy? The documented structure involves multiple tax classifications—501(c)(3) charities, 501(c)(4) social welfare organizations, and PACs—with money, staff, and resources moving between entities that professional auditors have determined require consolidated financial reporting due to operational integration.

The documented financial flows show large donors receiving 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 questions about whether such arrangements comply with federal prohibitions on tax-deductible political spending.

What oversight mechanisms exist when organizations processing massive revenue streams acknowledge operational unity in some contexts while maintaining separate legal structures that provide significant tax advantages? The documented financial flows represent approximately $400 million annually in potential tax implications.

Mamdani’s mayoral campaign demonstrates the operational effectiveness: over $2 million in PAC spending supported his candidacy—exceeding his entire direct campaign fundraising—while the supporting organizations maintained claims of independent operations despite documented coordination patterns.

The operational sophistication becomes evident when considering that 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.’

The documented ability to elevate candidates who publicly condemn billionaire influence while receiving support from billionaire-funded infrastructure raises questions about the mechanisms that enable such influence to operate through tax-exempt structures. If reducing billionaire influence in politics is the goal, shouldn’t that examination include the tax mechanisms documented in this investigation?

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

Part I: The Network Entities Mapping the $2+ billion operation: When professional auditors document operational relationships across multiple organizations

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

Part III: Documented Organizational Statements The direct evidence: When organizations document their own operational relationships in IRS filings

Part IV: The Elite Funding Pipeline – Following $693 Million Tracing documented financial flows: 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 documented personnel flows: When the same executives control “separate” charitable and political entities

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

Part IX: Regulatory Oversight Concerns Documented connections: Campaign Finance Board personnel with network relationships

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 documented coordination: Identical policies and shared systems across the network

Part XIV: The Network’s Documented Deployment – How the $2+ Billion Operation Supported Mamdani’s Campaign” The case study: When elite PAC spending exceeds the candidate’s entire grassroots fundraising

Part I: The Network Entities

This analysis examines financial flows and operational relationships documented in public filings across 20+ organizations controlling over $2 billion in assets. Professional audits document operational integration requiring consolidated financial reporting for some entities, while public filings show varying disclosure practices across the network. 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. 2023 Network Funding: Received $43,750 directly from Tides Center ($40,000) and Open Society Institute ($3,750)
Center for Popular Democracy Action Fund (501(c)(4)): Political advocacy arm receiving over $1 million in operational support. 2023 Network Funding: Received $700,000 from Open Society Policy Center for civic engagement activities. Total 2023 CDP Network Funding: $743,750.
Operational Integration Documentation: CDP Action Fund reports that “Center for Popular Democracy (501(c)(3)) serves as the common paymaster for all employees.” Both entities operate from shared facilities at 449 Troutman Street, Suite A, Brooklyn

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, distributing hundreds of millions globally
Documented Admissions: Open Society Institute’s IRS filings acknowledge operational relationships, shared facilities, and $36.4 million in transfers to political entities

Part II: The Documented Financial Process

The Four-Step Financial Flow Pattern

Analysis of public filings reveals a documented pattern of financial flows across entities with different tax classifications:

Step 1: Initial Funding

Tax-deductible donations flow to 501(c)(3) charitable organizations, while government grants provide additional funding streams (totaling over $16 million annually documented across the network).

Step 2: Transfer of Resources

These 501(c)(3) organizations transfer funds and provide operational support to their 501(c)(4) political advocacy affiliates. Professional audits document these transfers exceed $165,000 annually between related entities.

Step 3: Political Operations

The 501(c)(4)s engage in political advocacy and electoral activities, often distributing funds to affiliated PACs. Working Families Organization Inc. (501(c)(4)) distributed over $2.3 million to PACs in 2023. These entities also maintain bidirectional resource flows with their 501(c)(3) affiliates through documented cost-sharing arrangements.

Step 4: Policy Outcomes

Elected officials supported by this network advance policies that may result in continued government funding to network entities.

These documented financial flows raise questions about cash fungibility and operational independence. Under the “substance over form” doctrine established in Revenue Ruling 2007-41, tax law examines operational reality rather than legal formalities when evaluating organizational relationships.

Part III: Documented Organizational Statements

Working Families Party’s Published Framework

The Working Families Party’s published memo from November 2022 documents their understanding of campaign coordination requirements:

“WFP coordinated a significant grassroots IE table” (independent expenditures) and describes how they “brought the coalition back together from the primary” to support endorsed candidates in multiple contests.

This published documentation demonstrates the organization’s knowledge of coordination disclosure rules and regulatory requirements, providing context for evaluating subsequent disclosure practices.

Open Society Institute’s IRS Filing Disclosures

Open Society Institute (501(c)(3))’s IRS filings document bidirectional financial relationships with political entities:

Open Society Action Fund Inc. (501(c)(4)): $3,977,407 with filing stating “shared facilities & employees” with reimbursement arrangements

Fund for Policy Reform Inc. (501(c)(4)): $31,719,763 in transfers with documented shared operational arrangements

Fund for Policy Reform (501(c)(4)): $1,000,000 transfer

Total documented transfers in 2023: $36,462,230

Center for Popular Democracy’s Operational Documentation

The Center for Popular Democracy network’s filings document operational integration patterns:

Shared Personnel Documentation: 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”

Physical Integration: Both entities operate from 449 Troutman Street, Suite A, Brooklyn, alongside other network entities

Financial Pattern: CDP (501(c)(3)) distributed $1,411,940 throughout the network while receiving $545,202 in government grants (259% of grant revenue)

Network Integration: Received $743,750 from multiple network entities while simultaneously transferring $50,000 to Working Families Organization (501(c)(4))

These documented organizational statements and financial relationships, found in public filings and published communications, provide direct evidence of the operational arrangements and financial flows examined in this investigation.

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

The $1.13+ Billion Elite Political Infrastructure

Behind the network’s claimed grassroots authenticity lies a documented 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 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 complexity.

The Foundation to Promote Open Society – The Primary Funding Source

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

Foundation to Promote Open Society (501(c)(3)): Over $950 million in annual net investment income (2023)
Open Society Institute (501(c)(3)): $436.3 million in revenue (2023)
Open Society Action Fund Inc. (501(c)(4)): $257 million in revenue (2023)
Combined Annual Operation: $1.13+ billion in 2023 alone

The Documented Donor Flow Mechanism

The documented flows show how donor money to 501(c)(3) charities—which generates tax deductions—flows through to 501(c)(4) political operations through shared operational relationships:

Documented Network Flow Pattern:

Step 1: Open Society Institute provides documented 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 Structure Pattern: 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.

Documented Control Relationships Enable the Flow:

Professional auditors have documented operational integration that enables this funding mechanism:

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 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) operate 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
IRS Filing Admissions: Open Society Institute’s own Form 990-PF acknowledges “shared facilities & employees” with political entities while transferring $36.4 million

This operational unity enables the tax deduction mechanism 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 documented coordination across multiple entities funding the same recipient network, while CDP simultaneously operates as documented in this investigation—receiving government grants, distributing funds throughout the network, and maintaining the shared personnel and facilities that raise questions about organizational independence.

Beyond Soros – The Broader Pattern:

This mechanism extends beyond individual donors. The documented pattern shows:

Donors contribute to 501(c)(3) charities and receive tax deductions
Those charities transfer operational support to their 501(c)(4) political affiliates
Tax-deductible donations fund political operations through shared operational relationships

When the same individuals control both the charitable and political entities, the legal separation may not reflect operational reality.

Completing the Flow Pattern – Bidirectional Resource Sharing:

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 pays the salaries of political operatives
Open Society Example: Open Society Action Fund Inc. (501(c)(4)) 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 function as integrated entities—donors to the 501(c)(3) effectively subsidize 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 documented dual-channel process operating simultaneously through multiple 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 Documentation: The 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.

Seven-Year Documented Investment Pattern

According to Open Society Foundations’ public grant database, the network provided $7,612,750 in direct grants to core 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 the documented 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 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 Documentation

Independent professional auditors at two major accounting firms have documented operational integration and control deficiencies 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.

This “significant deficiency” in federal fund controls raises questions when these same organizations are transferring millions to political operations.

Withum Control Integration Documentation

Withum’s audit of Make the Road Network documented operational relationships, finding “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 Operational Integration

Both Withum and Deloitte auditors documented operational integration by treating legally separate entities as unified operations requiring consolidated financial reporting. This professional determination supports analysis under Revenue Ruling 2007-41—when independent auditors conclude that separate legal entities must be treated as unified operations for financial reporting purposes, this raises questions about examining operational reality rather than legal formalities for tax purposes.

Part VI: Government Grant Recipients with Political Operations

The Taxpayer Funding Documentation

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 documented 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 across the network.

This raises questions about oversight mechanisms 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 documentation 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 financial integration across the network.

Documented Funding Relationships:

Center for Popular Democracy (501(c)(3)) → Make the Road New York (501(c)(4)): $440,748 (creating direct 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 may free up other resources for political operations through cross-funding between related 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

This raises questions about oversight mechanisms when organizations processing these substantial federal expenditures simultaneously maintain the control deficiencies identified by professional auditors.

Part VII: Personnel Overlap and Dual Compensation

The Documented Personnel Integration

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 related entities

Daniel Altschuler – Political Operations:

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

The existence of a “Director of Politics” position within a 501(c)(3) charitable organization raises questions 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 – Personnel Flow Documentation:

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
Documentation: Direct pipeline from WFP political operations to campaign management for WFP-endorsed candidates

These documented personnel flows raise questions about operational unity across entities claiming separate status. From a “substance over form” perspective established in Revenue Ruling 2007-41, when the same individuals make strategic decisions across the entire pipeline, this raises questions about whether legal distinctions reflect operational reality.

IRC Section 4958 addresses excess compensation from tax-exempt organizations. These compensation packages across related entities raise questions about oversight when executives receive combined compensation exceeding $1.7 million.

Part VIII: The “Zero Employee” Operational Structure

The Documented Shared Services Arrangements

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

Evidence from Public Filings:

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 these arrangements and determined they require consolidated financial reporting due to operational integration. These documented shared services arrangements raise questions 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.

Part IX: Regulatory Oversight Concerns

Documented Regulatory Connections

Campaign Finance Board Personnel Documentation

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 documented 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 documented 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.

These documented connections raise questions about oversight integrity when regulators have connections to the entities they’re supposed to monitor.

Part X: Investment Income and Scale Considerations

The Scale of Tax-Free Operations

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

Investment Income Documentation:

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 operational relationships 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.

This scale of sophisticated offshore tax-exempt investment income generation raises questions when these assets support organizations that acknowledge operational relationships 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, this raises questions 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 operational relationships with political entities AND when organizations publish documentation of political campaign activities 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 documented 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 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, organizational admissions in IRS filings, and documented coordination patterns creates a framework for regulatory examination. These patterns raise questions about:

Whether operational unity documented by independent auditors raises questions about the organizational independence required for tax-exempt status
How cash fungibility principles apply when government grants may enable political activities through sophisticated financial arrangements
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 Documented Command Centers

Physical Address Documentation

Brooklyn Operations – 449 Troutman Street:

Suite A: Center for Popular Democracy (501(c)(3))
Suite A: Center for Popular Democracy Action Fund (501(c)(4))
Suite C: Make the Road Action Inc. (501(c)(4))

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

Working Families Organization Inc. (501(c)(4))
WFP National PAC (527)

San Francisco Network Hub – 1012 Torney Avenue:

Tides Network (501(c)(4))
Tides Center (501(c)(3))

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

Open Society Institute (501(c)(3))
Open Society Action Fund Inc. (501(c)(4))
Open Society Fund Inc. (501(c)(3))
Alliance for Open Society International Inc. (501(c)(3))

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
Financial transfers requiring coordinated financial planning

These shared operational systems raise questions 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, this raises questions under the “substance over form” doctrine established in Revenue Ruling 2007-41.

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

Part XIII: Enhanced Professional Service Integration

The Documented Infrastructure: Questions About Operational Independence

Cross-Network Professional Documentation

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

Documented 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

This level of administrative coordination raises questions about operational independence. When organizations maintain identical policies, coordinated filing processes, and shared professional service infrastructure, this raises questions about whether organizational independence required for tax-exempt status is maintained.

The documented nature of professional service coordination across entities processing over $2 billion annually suggests operational patterns 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, this raises questions 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 raises questions about 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 operations, present questions that remain within the purview of appropriate regulatory authorities to examine through established compliance review processes.

Part XIV: The Network’s Documented Deployment – How the $2+ Billion Operation Supported Mamdani’s Campaign

The Network’s Effectiveness in Action

The network’s effectiveness reaches its ultimate demonstration through Zohran Mamdani’s mayoral campaign, where the $2+ billion infrastructure supported 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 documented system provided 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.

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

Documentation of the Network’s Capabilities

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

Out-of-state tech billionaires provide $944,700 (71.5% of total funding)
Top donors: Mokhtarzada Brothers ($189,000), Rehan Muneeb-Azhar ($151,500), Moiz Ali ($100,000)
PAC spends $893,877 directly supporting Mamdani

The Government Grant Pipeline Supporting the Network’s Operations

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

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 Mathematical Precision Documentation

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 Strategy

Beyond the direct elite funding, the network generated additional taxpayer subsidies through NYC’s public campaign finance system:

Documented 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 Documentation

The network achieves its objectives through a documented cycle where elected officials support the programs that funded their rise:

Make the Road New York (501(c)(3)) 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 Documented Coordination

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

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

June 19, 2025: ADC contributes $5,000 to PAC
Same day: PAC spends exactly $5,000 on “ADC Billboard” items

Make the Road Action & WFP National PAC:

June 11, 2025: $45,697.14 same-day round-trip transaction

The Network’s Documented Success

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

Conclusion

Through documented admissions in their own IRS filings, professional audit evidence, and mathematical coordination patterns, this $2+ billion network has documented its own operational relationships that raise fundamental questions about the boundaries between charity and politics in America. When organizations acknowledge operational relationships 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 entities claiming independence, these patterns reveal sophisticated political operations operating under the guise of charitable work.

The network’s effectiveness demonstrates documented sophistication in creating authentic-seeming grassroots movements while maintaining operational control through tax-exempt mechanisms. Mamdani represents not an anomaly, but the system working as documented—a product created by a $2+ billion political operation that specializes in creating candidates who publicly condemn the very mechanisms that created them. Open Society Institute’s IRS filing admissions of operational relationships and $36.4 million in political transfers provide direct 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 operational relationships that warrant comprehensive regulatory response.

The documentation reveals an even more sophisticated funding architecture than initially documented. The network’s $7.61 million documented investment over seven years (2016-2023) in core network entities—including $743,750 in 2023 Center for Popular Democracy funding alone—demonstrates the documented 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 create 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 may exist primarily for regulatory advantage. The cash fungibility principle demonstrates how government grants may enable political activities by freeing up organizational resources, creating a mechanism where taxpayer funds indirectly subsidize elite political operations through sophisticated financial arrangements. 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 documented 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 with documented sophistication. The mathematical precision of coordination, combined with documented policy feedback loops, demonstrates a political operation capable of creating democratic legitimacy while obscuring its own elite foundations. The financial documentation—from OSI’s operational relationship admissions to CDP’s shared payroll systems—provides unprecedented direct evidence of this operational structure.

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, this raises questions about examining operational reality rather than legal formalities for tax purposes. When the same funding architecture that processes $7.61 million in documented elite investments simultaneously receives taxpayer grants and claims grassroots authenticity, this raises questions about the mechanisms that enable political power to operate through tax-exempt structures. These questions remain within the purview of appropriate regulatory authorities to investigate and address.

The documented patterns in this investigation were significant 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 operational relationships in public filings and published communications. The financial evidence strengthens this documentation: when organizations report shared payroll systems across charitable and political entities, when they acknowledge operational relationships in federal filings, and when they distribute resources at mathematical ratios that require external coordination, the evidence documents itself.

The integrity of the tax-exempt system and public confidence in democratic institutions requires examination of these patterns by appropriate regulatory authorities. When organizations document unified operations in their own tax filings while claiming independence, when professional auditors document operational integration, and when mathematically coordinated transactions occur, the evidence documents operational relationships. The documentation of $7.61 million in elite funding combined with over $16 million in government grants flowing through shared operational infrastructure demonstrates a scale of coordination that transcends individual campaign activities—this represents documented capture of democratic institutions through sophisticated financial arrangements designed to create grassroots legitimacy while obscuring 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 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

Table of Contents