The Soros-Mamdani Connection: How $34 Million in Tax-Exempt Flows Raise Questions About Charitable-to-Political Conversion

/ 46 minutes of reading

Following our comprehensive investigation that exposed a $2+ billion tax-exempt syndicate, our analysis of 2023 Form 990s uncovered breakthrough evidence of coordination patterns: documented reverse flows and systematic disclosure inconsistencies that raise questions about potential circumvention of tax law limitations. As with any complex financial investigation involving multiple entities and years of tax filings, our analysis has evolved as new documentation became available, with earlier reporting refined through deeper examination of the complete network structure.

This investigation builds on our previous reporting that exposed Zohran Mamdani’s Soros-funded elite network masquerading as a ‘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.

Here’s something that raises serious questions about legitimate charity work: recipients sending money back to their funders. The reverse flows were just the beginning—our latest discovery reveals $34,414,598 in documented flows between Tides entities with varying disclosure practices, including $29.3 million from the charitable Tides Foundation directly to the political advocacy arm Tides Advocacy—while Tides Advocacy systematically conceals key control relationships through Schedule R omissions.

The Coordination Pattern Standard: In standard charitable operations, money flows in one direction—from donors to charities to beneficiaries. When money starts flowing backward, from recipients back to funders, it raises questions about coordination rather than independence. The $325,000 in reverse flows we documented represent patterns that appear inconsistent with arm’s-length charitable relationships and suggest coordination that warrants investigation.

The Complete Flow System: Our investigation reveals patterns that raise questions about a sophisticated system where George Soros’s tax-deductible donations flow through 501(c)(3) charitable entities to 501(c)(4) political organizations, which then coordinate among themselves and send money back to the same charitable syndicate. Tides Advocacy (501(c)(4)) receives $29.3 million from Tides Foundation while filing no Schedule R whatsoever despite shared leadership and massive financial relationships, and coordinates with Working Families Organization (501(c)(4)), creating a network of political advocacy entities that systematically avoid transparency requirements. This creates patterns that suggest potential circumvention: George Soros → Foundation to Promote Open Society (501(c)(3)) → Tides Foundation (501(c)(3)) → Working Families Organization (501(c)(4)) → $325,000 BACK TO Tides entities, completing flows that raise questions about whether independent charitable organizations would create such circular patterns.

In 2023, Working Families Organization (501(c)(4)) received $9.71 million from the Soros/Tides syndicate through multiple channels, then sent $325,000 back to those same entities. Meanwhile, Tides Advocacy (501(c)(4))—itself receiving $29.3 million from Tides Foundation while filing no Schedule R to reciprocally disclose this relationship despite shared leadership—engaged in coordination with Working Families Organization, demonstrating patterns that suggest the network operates as a unified political system spanning multiple 501(c)(4) entities that avoid transparency requirements.

But as our investigation deepened, we discovered this reverse flow was just one component of a much larger flow system spanning the entire syndicate. Our latest analysis of Tides Foundation’s (501(c)(3)) Schedule I (from the most recent available tax filings) revealed flows on an unprecedented scale: $34,414,598 in direct transfers to related entities, including $29,312,169 to Tides Advocacy (501(c)(4))—an entity that shares key leadership with Tides Foundation but has filed no Schedule R whatsoever for at least five years despite receiving massive transfers and sharing control, enabling potential charitable-to-political conversion while completely concealing the control relationship that raises questions about whether such conversion occurs.

Additionally, $4,625,429 flowed to Tides Center (501(c)(3)), a properly disclosed related entity, under the identical program description “HEALTHY INDIVIDUALS AND COMMUNITIES.” This selective disclosure pattern—properly reporting relationships with entities like Tides Center while systematically concealing the control relationship with Tides Advocacy by filing no related organization disclosures whatsoever—demonstrates patterns that suggest intentional obfuscation designed to hide relationships that enable potential conversion of tax-deductible charitable donations into political advocacy operations. (Click on the image below to enlarge it.)

Soros Network Diagram

Critical Discovery: Pattern of Misaligned Employer Identification Numbers (EINs) – A key breakthrough in our investigation reveals systematic misalignment of Employer Identification Numbers in the financial filings of these organizations, providing objective evidence of reporting irregularities that raise serious questions about transparency and accuracy.

Tides Center EIN Issues: Tides Center (501(c)(3)) reported a $343,753 ‘contribution’ to ‘Tides Advocacy’ (501(c)(4)), but the EIN provided (81-3812257) actually belongs to Think Outside Da Block Inc. (501(c)(3))—a completely separate entity with a different tax classification. Multiple Tides Foundation and Tides Center filings identify this same EIN as the recipient of millions in grants under the name “Tides Advocacy,” raising fundamental questions about the true nature and destination of these funds.

This pattern of EIN misalignments across multiple organizations suggests systematic obfuscation rather than clerical errors—providing objective, verifiable evidence of reporting irregularities that warrant investigation.

Table of Contents

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

Part II: Understanding the Legal Framework – Why the IRS looks beyond paperwork: When “substance over form” meets cash fungibility

Part IIA: The Sophisticated Actor Standard – Evidence of potential willful intent: When experts who documented coordination knowledge engage in systematic patterns that raise compliance questions

Part III: The $9.71 Million Pipeline – How tax-deductible donations become political power through three sophisticated channels

Part IV: The Discovery That Raises Questions – When charities send money back to their funders: $34+ million in flows while key relationships remain concealed

Part V: When Numbers Don’t Add Up – The detailed breakdown: Why $34+ million in flows raise questions about systematic coordination

Part VI: When Tax Forms Contradict Themselves – False statements hiding in plain sight: Schedule R denials vs. Schedule I documentation

Part VII: The Shared Leadership Question – Same people, “separate” organizations: When CEOs control multiple entities claiming independence

Part VIII: Professional Audit Validation – When Deloitte confirms the coordination: Independent auditors document operational unity

Part IX: Explicit Admissions – What the organizations say about themselves: $36.4 million in “common control” transfers

Part X: Enhanced Syndicate Integration Evidence – When charities pay political operatives’ salaries: The shared command centers across Brooklyn and Manhattan

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

Part XII: What This Mathematical Evidence Reveals – Why $34+ million in flows raise questions about potential systematic compliance issues

Conclusion: The $500 Million Question – Why the IRS must examine evidence that raises serious compliance questions

The patterns suggest operational coordination across entities claiming separate status—coordination that, if confirmed, could represent one of the most sophisticated conversions of tax-deductible donations into political power ever documented.

Part I: The Syndicate Entities

Before examining the financial flows, it’s essential to understand the scale and structure of the entities involved. Professional auditors have documented what appears to be a coordinated syndicate operating under the guise of independent charitable and political organizations.

Working Families Party Syndicate

Working Families Organization Inc. (501(c)(4)): $48.8 million revenue (2023 Form 990, Part I, Line 12), reports 0 employees (2023 Form 990, Part V, Line 2a) while paying $11.04 million for personnel and administrative costs through shared services with other syndicate entities (2023 Form 990, Schedule O).

  • Working Families Party Building Account (PAC): Electoral support operations that received $2.2 million from Working Families Organization (501(c)(4)) for direct political spending (2023 Working Families Organization Form 990, Schedule I, Line 79).
  • WFP National Independent Expenditure Committee (Super PAC): Received $13,000 from Working Families Organization for unlimited independent expenditures supporting candidates like Mamdani (2023 Working Families Organization Form 990, Schedule I, Line 80). A key reporting irregularity shows that the EIN provided for this $13,000 grant (81-2160494) does not appear to be publicly verifiable, raising questions about the accuracy of this reporting.
  • WFP National PAC: Received $80,000 for ‘GNDN CONTRIBUTION TO COVER PA UNITED EXPENSE’ (2023 Working Families Organization Form 990, Schedule I, Line 81). A critical discovery shows that the EIN provided for this $80,000 grant (81-0941879) is actually associated with the International Earthlight Alliance, not the WFP National PAC. This misaligned reporting suggests patterns that raise questions about the accuracy of financial flows to political entities.

Tides Syndicate

Tides Foundation (501(c)(3)): $350,154,610 revenue (2023 Form 990, Part I, Line 12), $577,414,942 in net assets (2023 Form 990, Part I, Line 22), operates via shared services arrangement with Tides Network despite managing massive operations—operates under properly disclosed common control with Tides Center, requiring consolidated financial statements as confirmed by professional auditors

Tides Center (501(c)(3)): $233,700,520 revenue (2023 Form 990, Part I, Line 12) managing 140 fiscal sponsorship projects across the syndicate—shares CEO Janiece Evans-Page with Tides Foundation and operates under unified control confirmed by Deloitte audit.

Critical Disclosure Distinction: The Tides Foundation ↔ Tides Center relationship represents properly disclosed common control with shared leadership and professional audit validation, demonstrating legitimate disclosed relationships under applicable regulations.

Tides Advocacy (501(c)(4)): Political advocacy arm with systematic personnel overlap with the charitable entities, despite claims of independence—shares key leadership with Tides syndicate including Janiece Evans-Page as Director, but claims independence from the Tides entities under common control. Despite these documented relationships and receiving over $29 million from Tides Foundation, Tides Advocacy filed no Schedule R whatsoever for at least five years, systematically concealing these connections from federal oversight (2023 Form 990).

Open Society Syndicate

Open Society Institute (501(c)(3)): $436.3 million revenue (2023 Form 990-PF, Part I, Line 12), $4.54 billion in net assets (2023 Form 990-PF, Part II, Line 16)—the financial powerhouse that explicitly admits relationships with political entities on its own tax returns (2023 Form 990-PF, Part XVI, Lines 1b(4) and 1c), documenting $36.484 million in transfers to organizations, including Open Society Action Fund (501(c)(4)), that it describes as having “shared facilities & employees.”

Open Society Action Fund (501(c)(4)): Direct political funding arm that provided $5.15 million to Working Families Organization (501(c)(4)) (2023 Form 990, Schedule I, Lines 228 and 229).

Foundation to Promote Open Society (501(c)(3)): $3.49+ billion in investment assets generating massive tax-free returns to fund the syndicate—with $10,199,669,983 in net assets (2023 Form 990-PF, Part II, Line 16) and a direct funding source we discovered that dramatically expands the pipeline scale.

Syndicate Integration Entities

Center for Popular Democracy (501(c)(3)): $28.68 million revenue (2023 Form 990, Part I, Line 12) that distributes 259% of its government grant revenue throughout the syndicate—a pattern that raises questions about external coordination enabling this resource distribution beyond what government grants alone could support.

Make the Road New York (501(c)(3)): $31.76 million revenue (2023 Form 990, Part I, Line 12) with $16.1 million in government grants (52% of total revenue) (2023 Form 990 Part VIII, Line 1e) while simultaneously transferring funds to political advocacy arms.

Syndicate Scale and Control

Total Operation: $2+ billion annually across all entities
Total Assets: $11+ billion generating tax-free investment income
Personnel Integration: Same executives control multiple entities claiming independence
Physical Integration: Shared addresses in Brooklyn and Manhattan command centers
Professional Validation: Independent auditors document operational unity across the network, while entities like Tides Advocacy systematically avoid required disclosures despite shared control

Part II: Understanding the Legal Framework

Before examining the financial flows, two key principles help explain why these patterns matter under federal tax law

The Systematic Four-Step Conversion Process

Investigation reveals patterns that raise questions about a sophisticated system that may demonstrate how charitable donations and government grants systematically relate to political campaign support:

Step 1: Initial Funding
George Soros donates to Foundation to Promote Open Society (501(c)(3)) receiving tax deductions for his contributions, while simultaneously taxpayer money flows into network entities through government grants totaling over $16 million annually. Mathematical Evidence: Make the Road New York receives $16.1 million in government grants (52% of total revenue) while Center for Popular Democracy (501(c)(3)) received $545,202 in government grants while distributing $1,411,940 throughout the network—259% of its government grant revenue, a mathematical impossibility without external coordination proving systematic integration of government-subsidized resources.

Step 2: Transfer of Resources
Foundation to Promote Open Society (501(c)(3)) transfers $8.4 million to Tides Foundation (501(c)(3)), which then transfers $29.3 million to Tides Advocacy (501(c)(4)) under identical “Healthy Individuals and Communities” program descriptions while Tides Advocacy systematically conceals this relationship through Schedule R omissions. Critical Violation: Despite sharing key leadership (Janiece Evans-Page serves as Director of Tides Advocacy while simultaneously serving as CEO and Director of Tides Network and CEO of both Tides Center and Tides Foundation), Tides Advocacy files no Schedule R whatsoever for five years—systematic concealment enabling conversion of tax-deductible charitable donations into political advocacy operations.

Step 3: Political Action
Tides Advocacy (501(c)(4)) coordinates with Working Families Organization (501(c)(4)) which distributes $2.3 million to PACs for direct political spending, while Working Families Organization sends $325,000 back to Tides entities completing coordination patterns. Mathematical Proof: $325,000 in reverse flows from Working Families Organization back to Tides entities after receiving $9.71 million through the pipeline—coordination patterns that independent charitable organizations would never engage in, creating bidirectional resource flows that demonstrate complete operational integration while denying relationships on federal tax returns.

Step 4: Policy Feedback Loop
Candidates like Zohran Mamdani supported by this network advance policies that result in more taxpayer funds flowing back to the same charitable entities, creating a systematic self-perpetuating cycle that converts public resources into political power through concealed coordination while maintaining the appearance of independent charitable operations for tax purposes.

This pattern raises questions about whether the 501(c)(3) charitable entities serve as mechanisms that may enable tax-deductible donations to ultimately support political activities.

Substance Over Form

Under Revenue Ruling 2007-41, the IRS examines operational reality rather than legal formalities when evaluating organizational independence. When the same individuals control financial decisions across supposedly independent entities, when organizations share facilities and personnel systems, and when professional auditors determine that legally separate entities must be treated as unified operations for financial reporting purposes, these factors raise questions about whether the legal separation reflects operational reality or exists primarily for tax advantages.

Cash Fungibility

Money is interchangeable. Even if organizations claim private donations fund political activities while government grants support charitable work, the influx of millions in taxpayer funding frees up other funds and operational capacity for political advocacy. This principle explains how government grants may indirectly subsidize political operations through sophisticated financial engineering—creating a mechanism where taxpayer funds help underwrite political coordination despite claims of proper segregation.

These principles become crucial when examining the coordination patterns we discovered across the syndicate.

Part IIA: The Sophisticated Actor Standard – Evidence of Willful Intent

What transforms this case from potential oversight to patterns raising compliance questions is the Working Families Party’s own documentation of their sophisticated understanding of campaign coordination requirements. Their knowledge of these rules makes their subsequent coordination patterns evidence of potential willful issues rather than inadvertent problems.

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 examination: WFP’s published documentation demonstrates their comprehensive knowledge of coordination disclosure rules and requirements. This expertise makes their subsequent coordination patterns documented in 2023 tax filings (the most recent available) warrant examination—they were fully aware of the regulatory framework that raises questions about their compliance.

Documented Operational Sophistication

The 2022 memo reveals the scope of WFP’s coordination expertise:

  • Multi-state coordination: “WFP ran a major field mobilization in four crucial Senate battlegrounds”
  • Scale operations: “We knocked on 400,000 doors in Pennsylvania” and “held a 1,000-person phone bank”
  • Independent expenditure management: Understanding of IE tables and coalition coordination
  • Strategic coalition building: Bringing “the coalition back together from the primary”

Legal Significance: The “Sophisticated Actor” Doctrine

Under federal law, organizations demonstrating sophisticated knowledge of regulatory requirements face heightened scrutiny for subsequent violations. The 2022 memo establishes that:

  • WFP possessed detailed knowledge of coordination disclosure requirements and operational frameworks
  • They successfully managed complex multi-state coordination while maintaining compliance disclosures
  • Their 2023 patterns while denying relationships appear to represent potential willful issues by parties who demonstrably knew the rules
Potential Criminal Intent Implications: When an organization documents sophisticated knowledge of coordination requirements in 2022, then engages in $34.4+ million flows while systematically denying relationships in their 2023 tax filings (the most recent available), this pattern raises serious questions about potential willful intent that warrant investigation. The combination of demonstrated regulatory expertise and subsequent contradictory disclosures creates a factual record that supports examination under IRC Section 7206(1) standards for willful false statements, though determination of criminal intent requires prosecutorial review.

Part III: The Funding Pipeline: Tracing $9.71 Million

To understand why the reverse flows are so significant, we must first trace the funding pipeline that made them possible. Our investigation of the Foundation to Promote Open Society’s 2023 tax filings (the most recent available) revealed a funding system spanning multiple channels that enables the patterns we documented across the network.

Channel 1: The Expanded Charitable Route

George Soros → Multiple Open Society Entities (501(c)(3)) → Tides Foundation (501(c)(3)) → Working Families Organization (501(c)(4))
Foundation to Promote Open Society (501(c)(3)) to Tides Foundation (501(c)(3)):

Foundation to Promote Open Society (501(c)(3)) to Tides Center (501(c)(3)):

Combined Foundation to Promote Open Society Network to Tides Network: $8.4 Million

Channel 2: Direct Political Funding

Open Society Action Fund (501(c)(4)) → Working Families Organization (501(c)(4))

Channel 3: Network Coordination Flows

Multiple patterns across the network revealed financial flows that raise questions about operational independence, including reciprocal transactions:

Note: Tides Foundation and Tides Center operate under properly disclosed common control with shared CEO Janiece Evans-Page and consolidated financial reporting confirmed by Deloitte audit. However, Tides Advocacy (501(c)(4)) shares key leadership with the Tides entities (Janiece Evans-Page serves as Director of Tides Advocacy while simultaneously serving as CEO and Director of Tides Network and CEO of both Tides Center and Tides Foundation) yet files no Schedule R whatsoever despite these relationships and receiving substantial transfers from entities under common control.

Total Working Families Organization Pipeline: $9.71 Million
Total Funding to Tides Network: $8.40 Million

The scale of this funding pipeline across the network raises fundamental questions about the independence claims made by entities that systematically avoid required relationship disclosures. The $9.71 million pipeline demonstrates the scope of financial flows spanning charitable and political entities while concealing key control relationships that raise questions about operational coordination.

The Ultimate Flow Pattern

The documented funding flows reveal a pattern where resources originating from George Soros move through multiple entities with different tax classifications:

Soros → 501(c)(3) Entities → 501(c)(4) Entities → Political Operations

  • Foundation to Promote Open Society (501(c)(3)) provides $8.4M to Tides Network
  • Tides Foundation (501(c)(3)) transfers $4.56M to Working Families Organization (501(c)(4))
  • Working Families Organization (501(c)(4)) distributes $2.3M to PACs and political committees
  • Open Society Action Fund (501(c)(4)) provides additional $5.15M directly to Working Families Organization (501(c)(4))

This pattern raises questions about whether the 501(c)(3) charitable entities serve as pass-through mechanisms that enable tax-deductible donations to ultimately support political activities—flows that appear designed to circumvent the tax code’s restrictions on political use of charitable funds.

Legal Significance: The documented flows suggest a system where donors receive tax deductions for contributions to charitable entities, which then transfer substantial funds to political advocacy organizations, potentially undermining the tax code’s distinction between charitable and political activities.

The Political Conversion

The ultimate destination of the pipeline funding becomes clear in Working Families Organization’s (501(c)(4)) 2023 Schedule I (from the most recent available tax filings), which distributed funds directly into political operations:

The Scale of Resource Flow: The $9.71 million pipeline reveals how Soros entities provide funding to Tides Foundation through multiple channels, which then transfers $4.56 million to Working Families Organization (501(c)(4))—while key relationships enabling this system remain undisclosed through Schedule R omissions.

Part IV: The Discovery That Raises Questions

Breakthrough Discovery Sequence: What began as routine analysis of $325,000 in reverse flows quickly revealed something far more significant. Our comprehensive investigation of the latest available tax filings (2023) uncovered $34,007,598 in documented flows between entities with varying disclosure practices, including $29.3 million from the charitable Tides Foundation directly to the political advocacy arm Tides Advocacy—flows that raise questions about one of the largest potential conversions of tax-deductible charitable assets into political advocacy operations while key relationships remain systematically concealed.

The $34+ Million Flow System

Our comprehensive analysis of Tides Foundation’s 2023 Schedule I revealed flow patterns that dwarf the initial reverse flows we documented. The scale raises fundamental questions:

Tides Foundation (501(c)(3)) 2023 Schedule I Major Flows:

  • Tides Advocacy (501(c)(4)) (Line 2041): $29,312,169 for “HEALTHY INDIVIDUALS AND COMMUNITIES”
  • Tides Center (501(c)(3)) (Line 2042): $4,625,429 for “HEALTHY INDIVIDUALS AND COMMUNITIES”
  • Tides Inc (Line 2043): $70,000 for “EQUITY, HUMAN RIGHTS, AND ECONOMIC EMPOWERMENT”
  • Total Major Flows: $34,007,598

The Critical Disclosure Distinction

The significance of these flows becomes clear when examining disclosure patterns across the network:

Properly Disclosed Relationships:

  • Tides Foundation ↔ Tides Center: Properly disclosed common control with shared CEO Janiece Evans-Page
  • Professional validation: Deloitte audit confirms operational unity requiring consolidated reporting
  • Schedule R compliance: Both entities properly disclose their control relationships

Systematically Concealed Relationships:

  • Tides Advocacy: Shares key leadership with Tides entities (Janiece Evans-Page serves as Director of Tides Advocacy while simultaneously serving as CEO and Director of Tides Network and CEO of both Tides Center and Tides Foundation)
  • Schedule R omissions: Files no Schedule R whatsoever for 5+ years despite these relationships and receiving $29.3M transfer
  • Operational integration: Functions within the same network while claiming independence

The “Healthy Individuals and Communities” Pattern

The most significant aspect of these massive transfers is the identical program descriptions combined with systematic disclosure omissions by the political recipient:

 

Why This Pattern Raises Legal Questions:

  • 501(c)(3) = Tax-deductible donations with strict prohibition on political campaign intervention
  • 501(c)(4) = Political advocacy allowed but donations are NOT tax-deductible
  • $29.3 million flow: Tax-deductible charitable donations flowing directly to political advocacy operations
  • Identical program descriptions: Suggests coordinated program management rather than independent charitable decisions
  • Systematic concealment: Tides Advocacy files no Schedule R despite shared leadership and massive transfers

The Core Compliance Question: Donors received $29.3 million in tax deductions for contributions to Tides Foundation (501(c)(3)), which then transferred those tax-deductible funds directly to Tides Advocacy (501(c)(4)) under identical program descriptions—while Tides Advocacy systematically conceals its control relationships through Schedule R omissions, raising questions about potential circumvention of tax law designed to prevent this type of conversion.

The Complete Flow Network: $34.4 Million

Our analysis uncovered financial flows spanning multiple directions between entities with varying disclosure practices:

Tides Foundation (501(c)(3)) Major Flows ($34,007,598):

  • Tides Foundation (501(c)(3)) → Tides Advocacy (501(c)(4)): $29,312,169 (“Healthy Individuals and Communities”)
  • Tides Foundation (501(c)(3)) → Tides Center (501(c)(3)): $4,625,429 (“Healthy Individuals and Communities”)
  • Tides Foundation (501(c)(3)) → Tides Inc: $70,000 (“Equity, Human Rights, and Economic Empowerment”)

Disclosed Tides Center ↔ Tides Foundation Operational Integration:

Working Families Organization (501(c)(4)) Network Flows:

Additional Network Integration:

Total Documented Network Flows: $34,414,598

Professional Validation of Disclosed Relationships:

  • $5,634,644 reciprocal flows between Tides Foundation (501(c)(3)) and Tides Center (501(c)(3)) properly disclosed as operational integration between entities under documented common control

The Compliance Question: When entities engage in $34+ million flows while some properly disclose relationships and others systematically conceal them, this raises fundamental questions about whether undisclosed control relationships enable circumvention of tax law limitations. The $29.3 million transfer from Tides Foundation (501(c)(3)) to Tides Advocacy (501(c)(4)) under identical program descriptions, combined with Tides Advocacy’s systematic Schedule R omissions despite shared leadership, demonstrates patterns that appear inconsistent with required independence between charitable and political entities.

These flow patterns become difficult to reconcile with claims of independence when supposedly separate entities engage in multi-directional funding totaling over $34 million spanning both charitable and political classifications—while systematically concealing key control relationships through Schedule R omissions despite sharing the same leadership across multiple entities.

Part V: When Numbers Raise Questions

The documented flows revealed in Part IV were only the beginning. As we examined the syndicate’s 2023 IRS filings more comprehensively, patterns emerged that raise fundamental questions about operational independence. The scale appears difficult to reconcile with independent charitable operations.

Tides Foundation (501(c)(3)) Major Documented Flows ($34,007,598):

Working Families Organization (501(c)(4)) Reverse Flows ($325,000):

The $29.3 Million Flow Pattern

The $29.3 million transfer from Tides Foundation (501(c)(3)) to Tides Advocacy (501(c)(4)) represents one of the largest documented flows raising questions about potential conversion of tax-deductible charitable assets into political advocacy funding. This pattern raises several compliance questions:

  • Tax Deduction Framework Questions: Donors received tax deductions for $29.3 million contributed to charitable Tides Foundation, which then transferred the funds to political advocacy operations, raising questions about the tax code’s intended separation
  • 501(c)(3)/501(c)(4) Classification Concerns: The tax code creates separate categories with different restrictions, and this flow pattern raises questions about whether those distinctions are being maintained operationally
  • Identical Program Management: Using identical “Healthy Individuals and Communities” descriptions suggests coordinated program management that raises questions about independent charitable decision-making
  • Scale of Operations: $29.3 million exceeds the entire annual budgets of most political advocacy organizations, demonstrating patterns that appear inconsistent with incidental charitable support

Legal Significance: When a 501(c)(3) transfers $29.3 million to a 501(c)(4) under identical program descriptions while sharing the same CEO (Janiece Evans-Page) and the recipient systematically conceals the relationship through Schedule R omissions, these patterns raise questions about whether the legal separation reflects operational reality or exists primarily to circumvent tax law limitations on political use of tax-deductible donations.

What is Schedule I?

Schedule I requires organizations to list all grants made during the tax year. While organizations can legitimately support related causes, the direction and pattern of grants can reveal operational relationships that organizations might prefer to keep hidden.

The patterns extended beyond isolated incidents. The flows between Tides entities appeared throughout the related filings, creating broader patterns that warrant examination.

The Critical Distinction: Disclosed vs. Concealed

Properly Disclosed Tides Foundation ↔ Tides Center Integration:

Systematically Concealed Tides Advocacy Integration:

The “Healthy Individuals and Communities” Question Pattern:

  • Total 501(c)(3) → 501(c)(4) Flows: $29,655,922 (Tides Foundation $29,312,169 + Tides Center $343,753)
  • All under identical program descriptions suggesting coordinated program management
  • Same CEO (Janiece Evans-Page) involved across all entities in the flow pattern
  • Systematic concealment: Political recipient avoids required relationship disclosures despite operational integration

Additional Evidence from Network Filings:

Total Documented Network Flows: $34,758,351

The Compliance Framework Question

The pattern that emerges raises fundamental questions about operational independence:

Legitimate Disclosed Operations: The $5.6 million reciprocal flows between Tides Foundation (501(c)(3)) and Tides Center (501(c)(3)) represent properly disclosed operational integration between entities under documented common control, with professional audit validation confirming the legitimacy of these arrangements.

Questionable Concealed Operations: The $29.7 million flows to Tides Advocacy (501(c)(4)) raise compliance questions because they involve identical program descriptions, shared leadership, and systematic concealment of relationships that would normally require Schedule R disclosure.

The distinction becomes crucial: entities can have relationships and shared operations if properly disclosed and validated. The compliance questions arise when entities systematically conceal control relationships while claiming independence, particularly when those concealed relationships enable flows that appear designed to circumvent tax law distinctions between charitable and political activities.

Part VI: When Tax Forms Raise Disclosure Questions

Beyond the documented flows, our investigation revealed patterns in disclosure practices that raise questions about reporting accuracy. The contrasts become apparent when examining different sections of the same IRS filing and comparing Schedule R responses across the network. Working Families Organization’s (501(c)(4)) 2023 tax return presents what appears to be internally inconsistent statements, while Tides Foundation’s Schedule R documents relationships that raise questions about network-wide disclosure practices.

What is Schedule R?

IRS Schedule R requires tax-exempt organizations to disclose relationships with related entities. The form helps the IRS determine whether organizations truly operate independently or function as components of a larger system. False statements on this form can carry criminal penalties.

The Disclosure Pattern Questions

The contrast becomes apparent when comparing disclosure practices across the network – while some entities provide comprehensive relationship disclosures, others appear to systematically omit similar information:

Working Families Organization Schedule R Responses (all marked “No”) – 2023 Working Families Organization Schedule R:

  • Line 25a: “Sharing of facilities, equipment, mailing lists, or other assets with related organization(s)” (2023 Working Families Organization Form 990, Schedule R, Line 25a)
  • Line 25b: “Sharing of paid employees with related organization(s)” (2023 Working Families Organization Form 990, Schedule R, Line 25b)
  • Line 26: “Reimbursement paid to related organization(s) for expenses” (2023 Working Families Organization Form 990, Schedule R, Line 26)

Tides Foundation Schedule R Responses (all marked “Yes”) – 2023 Tides Foundation Schedule R:

  • Line 1n: “Sharing of facilities, equipment, mailing lists, or other assets with related organization(s)” – YES
  • Line 1o: “Sharing of paid employees with related organization(s)” – YES
  • Line 1p: “Reimbursement paid to related organization(s) for expenses” – YES
  • Line 1q: “Reimbursement paid by related organization(s) for expenses” – YES
  • Line 1b: “Gift, grant, or capital contribution to related organization(s)” – YES
  • Line 1c: “Gift, grant, or capital contribution from related organization(s)” – YES

The Documentation Standard: Tides Foundation’s Comprehensive Disclosure

Tides Foundation’s Schedule R Part V demonstrates comprehensive relationship documentation, specifically detailing millions in transactions with network entities:

Tides Foundation Schedule R Part V – Documented Related Organization Transactions:

  • TIDES CENTER – Transaction Type M: $100,150
  • TIDES CENTER – Transaction Type C: $5,634,644
  • TIDES CENTER – Transaction Type B: $4,625,429
  • TIDES CENTER – Transaction Type P: $341,936
  • TIDES INC – Transaction Type B: $70,000
  • Total Documented Transactions: $10,772,159

Context: Working Families Organization (501(c)(4)) Network Flows (same time period):

The Systematic Pattern: Tides Advocacy’s Five-Year Omission

The most significant disclosure pattern involves Tides Advocacy (501(c)(4)), which shares key leadership with Tides entities (Janiece Evans-Page serves as Director of Tides Advocacy while simultaneously serving as CEO and Director of Tides Network and CEO of both Tides Center and Tides Foundation) yet systematically files no Schedule R whatsoever despite:

  • Receiving $29.3 million from Tides Foundation in 2023
  • Sharing leadership across multiple entities
  • Operating within the same network for 5+ years
  • Engaging in reciprocal financial flows with network entities

This five-year pattern of Schedule R omissions raises questions about whether disclosure requirements are being systematically avoided to conceal relationships that would normally require reporting.

Critical Discovery: EIN Reporting Irregularities

Beyond Schedule R questions, the investigation revealed systematic EIN discrepancies that provide objective, verifiable evidence of reporting irregularities. Working Families Organization’s 2023 Schedule I contains striking EIN inconsistencies:

Similarly, Tides Center reported a $343,753 ‘contribution’ to ‘Tides Advocacy’ but the EIN provided (81-3812257) actually belongs to Think Outside Da Block Inc. (501(c)(3))—a completely separate entity with a different tax classification.

The Compliance Framework Question

The contrast raises fundamental questions about disclosure consistency. Working Families Organization systematically denies related organization relationships while sending $325,000 to Tides entities, while Tides Foundation simultaneously provides comprehensive relationship documentation including over $10.7 million in transactions with the same network entities. Combined with systematic EIN reporting irregularities across multiple filings, these patterns suggest potential coordination in disclosure practices that warrants investigation.

Additional Context from Schedule R: Working Families Organization (501(c)(4)) reports $11.04 million in “personnel and administrative costs through shared services arrangements” while claiming zero employees (2023 Working Families Organization Form 990, Schedule R).

The Legal Framework Context

The IRS allows related organizations and shared services, but requires proper disclosure. The apparent contradictions within the same filing, combined with systematic EIN reporting irregularities, raise questions about disclosure accuracy that may warrant examination under IRC Section 7206(1) standards for willful false statements, though determination of intent requires prosecutorial review.

The disclosure patterns suggest a coordinated approach where some entities provide comprehensive relationship documentation while others systematically omit similar disclosures, raising questions about whether this represents a strategy designed to obscure the operational reality of network coordination while maintaining the appearance of independent operations for tax purposes.

Part VII: The Shared Leadership Question

As our investigation continued, the complexity deepened when we examined personnel overlap across entities claiming independence. According to the organizations’ own Schedule O filings, key individuals serve in leadership roles across multiple entities claiming separate tax-exempt status—yet these relationships are systematically omitted from required disclosures.

Understanding the Tax Code Violation

  • 501(c)(3) organizations receive tax-deductible donations but face strict limits on political activity
  • 501(c)(4) organizations can engage in political advocacy but donations aren’t tax-deductible
  • The $29.3 Million Flow Pattern: Tax-deductible donations to Tides Foundation (501(c)(3)) transferred directly to Tides Advocacy (501(c)(4)) raise compliance questions
  • Legal Requirement: These must operate independently when claiming separate exempt status

The personnel overlap we discovered is extensive and systematic:

Janiece Evans-Page appears on filings for:

Critical Violation: Despite Janiece Evans-Page serving as Director of Tides Advocacy while simultaneously controlling the other three Tides entities as CEO, Tides Advocacy has systematically filed no Schedule R disclosures for over five years while claiming complete independence. This systematic concealment of documented control relationships suggests potential conversion of tax-deductible charitable donations into political advocacy operations, while obscuring a unified command structure that raises serious compliance questions about the required independence of separate tax-exempt entities.

Part VIII: Professional Audit Findings: Independent Validation

At this point, a reasonable person might wonder whether our analysis represents mere speculation based on document review. That question was answered definitively by an unexpected source: the organizations’ own professional auditors.

Deloitte & Touche’s 2023 audit of Tides Organizations (501(c)(3)) provides independent, third-party validation of the coordination patterns we documented in tax filings. Professional auditors, with full access to internal records and operations, reached the same conclusions our mathematical analysis suggested.

Key Findings from 2023 Audit:

  • “Network is the sole member and appoints board members” across entities (2023 Deloitte Audit of Tides Organizations, p. 8)
  • Consolidated financial statements required due to operational control (2023 Deloitte Audit of Tides Organizations, Note 1)
  • Finding 2023-001: “Significant deficiency” in federal expenditure controls over $16.2 million (2023 Deloitte Audit of Tides Organizations, Finding 2023-001)
  • 290 employees providing services across multiple entities through centralized structure (2023 Deloitte Audit of Tides Organizations, Note 12)

Additional Control Deficiency Evidence:

The 2023 Tides audit identified Finding 2023-001, documenting systematic control gaps where “not all program expenditures were reported in the correct year” across $16.2 million in federal expenditures. The audit found that “expenses previously recorded and reported as use of unrestricted funds were later identified as federal grant expenditures,” with one case where “the federal grant was awarded four months after the end of the fiscal period in which the expenditures were incurred, impeding identification for inclusion in the SEFA.”

This creates a Corrective Action Plan requiring Tides to “reinforce existing policies and procedures to recognize federal expenditures as they occur with additional focus on reporting program expenditures in the year expenditures were incurred.” The question becomes unavoidable: what does this “significant deficiency” in federal fund controls mean when these same organizations are simultaneously transferring millions to political operations while managing $16.2 million in federal expenditures?

Audit Significance: When independent auditors determine that legally separate entities must be treated as unified operations for financial reporting purposes, this raises fundamental questions about whether the same operational reality should govern tax-exempt status determinations.

The professional audit findings corroborate what our mathematical evidence suggests: operational unity disguised through legal separation, validated by independent certified public accountants with full access to internal operations.

Part IX: Explicit Admissions: What the Organizations Say About Themselves

Perhaps most remarkably, our investigation uncovered that some organizations have explicitly documented the very relationships that appear to contradict their claims of independence—including direct admissions from the funding source for the pipeline we traced.

Part XVI Documentation

Open Society Institute’s (501(c)(3)) 2023 Form 990-PF, Part XVI provides the most explicit admissions about systematic political coordination. Part XVI specifically asks about “transfers to and transactions and relationships with noncharitable exempt organizations” relating to “political organizations.” Open Society Institute answered “Yes” to both sharing arrangements and reimbursement arrangements, then documented the precise details:

Open Society Action Fund Inc (501(c)(4)): $4,000,000

Fund for Policy Reform Inc. (501(c)(4)): $31,484,823

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

Total Open Society Institute (501(c)(3)) Political Transfers: $36,484,823

Part XVI Legal Significance: This form section specifically asks about “transfers to and transactions and relationships with noncharitable exempt organizations” relating to “political organizations.” Open Society Institute answered “Yes” to both Line 1b(4) (reimbursement arrangements) and Line 1c (sharing of facilities, equipment, mailing lists, other assets, or paid employees) – documenting systematic operational integration with political entities while claiming charitable status.

The Pipeline Connection

Open Society Institute’s (501(c)(3)) 2023 Form 990-PF also contains additional explicit admissions in Schedule R about its relationships with political entities. These aren’t inferences or interpretations—they’re explicit statements in the organization’s own tax filing.

Open Society Action Fund Inc (501(c)(4)): $4,000,000

Fund for Policy Reform Inc. (501(c)(4)): $31,484,823

  • Line 1b(4): $765,060 – “Fund for Policy Reform Inc. REIMBURSES IN ADVANCE Open Society Institute FOR ITS ALLOCABLE SHARE OF EXPENSES” (2023 Open Society Institute Form 990-PF, Part XVI, Line 1b(4))
  • Line 1c: $30,719,763 – “SHARE OF OVERHEAD, SALARY & BENEFITS” (2023 Open Society Institute Form 990-PF, Part XVI, Line 1c)

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

  • Line 1c: $1,000,000 – “SHARE OF OH, SALARY & BENEFITS” (2023 Open Society Institute Form 990-PF, Part XVI, Line 1c)

Total Open Society Institute (501(c)(3)) Political Transfers: $36,484,823

Part XVI Legal Significance: This form section specifically asks about “transfers to and transactions and relationships with noncharitable exempt organizations” relating to “political organizations.” Open Society Institute answered “Yes” to both Line 1b(4) (reimbursement arrangements) and Line 1c (sharing of facilities, equipment, mailing lists, other assets, or paid employees) – documenting systematic operational integration with political entities while claiming charitable status.

The Pipeline Connection

These admissions create an irreconcilable contradiction. When the organization that admits “common control” with $36.5 million in political transfers is simultaneously funding the charitable pipeline that reaches Working Families Organization (501(c)(4)) with $9.71 million through Tides Foundation, it raises fundamental questions about whether the entire pipeline operates under coordinated control rather than as independent charitable operations.

  • George Soros → Multiple Open Society Entities (501(c)(3)) → Tides Foundation (501(c)(3)) → Working Families Organization (501(c)(4))

While the IRS permits relationships between tax-exempt entities, explicit admissions of “common control” combined with systematic funding of pipelines that end in political operations raise fundamental questions about operational independence.

When the funding organization itself legally admits “common control,” “shared facilities,” and “shared employees” with political advocacy groups while simultaneously funding charitable pipelines, this suggests the entire syndicate operates as a unified political system disguised through legal separation.

These explicit admissions, combined with additional coordination evidence, create a pattern that eliminates the need for regulatory interpretation—the organizations have documented their own violations.

Additional Open Society Coordination Evidence:

Beyond the $36.5 million in admitted political transfers, our investigation revealed extensive additional coordination between Open Society entities and the Tides network:

Foundation To Promote Open Society (501(c)(3)) Additional Tides Funding (2023 Foundation to Promote Open Society IRS Form 990-PF, Section XIV):

  • $300,000 to Tides Center for International Corporate Accountability Roundtable
  • $1,000,000 to Tides Center for Maria Fund (Puerto Rico organizing)
  • $410,000 to Tides Center for strategic legal and advocacy campaigns
  • $250,000 to Tides Center for 22nd Century Initiative (anti-authoritarianism organizing)
  • Additional grant to Tides Foundation for Maria Fund (amount not specified)

Open Society Action Fund (501(c)(4)) Direct Political Coordination with Tides Advocacy (Open Society Action Fund IRS Form 990, Schedule I):

  • $3,000,000 to Tides Advocacy (501(c)(4)) for social welfare activities in Michigan (Line 208)
  • $350,000 to Tides Advocacy (501(c)(4)) for Advance Native Political Leadership Action Fund (Line 204)
  • $250,000 to Tides Advocacy (501(c)(4)) for Asian American and Pacific Islander civic engagement (Line 205)
  • $250,000 to Tides Advocacy (501(c)(4)) for Life After Release (Maryland justice reform) (Line 206)
  • $200,000 to Tides Advocacy (501(c)(4)) for nonpartisan civic engagement in Texas (Line 207)
  • $150,000 to Tides Advocacy (501(c)(4)) for Electoral Justice Project (Line 203)
  • $100,000 to Tides Advocacy (501(c)(4)) for prosecutorial reform advocacy (Line 209)

Total Additional Documented Coordination: $6.26 million

This brings the total documented Open Society → Tides coordination to over $19.5 million in 2023 alone, demonstrating systematic integration far beyond the pipeline we initially traced.

Part X: Enhanced Network Integration Evidence

Our investigation revealed that operational integration extends beyond the core pipeline to encompass patterns across multiple network components. The documentation reveals organizational arrangements that raise questions about the operational independence claimed by entities seeking separate tax-exempt status.

Center for Popular Democracy Integration Documentation

Center for Popular Democracy Action Fund (501(c)(4)) explicitly reports that “Center for Popular Democracy serves as the common paymaster for all employees”—documenting that the charitable entity directly pays political operatives’ salaries (2023 Center for Popular Democracy Action Fund Form 990, Schedule J). This admission demonstrates resource fungibility across entities claiming separate tax-exempt status.

Alliance for Open Society International: Comprehensive Integration Disclosure

Alliance for Open Society International’s 2023 Schedule O provides comprehensive documentation of operational integration that demonstrates the transparency standard for complex organizational arrangements: “Employees of Open Society Institute (OSI), a related section 501(c)(3) tax exempt organization, are seconded to AOSI and some serve as officers of AOSI.” The Schedule O further documents:

  • Shared Personnel System: “Open Society Institute maintains on its payroll and benefit plans certain employees who provide services to Alliance for Open Society International”
  • Shared Facilities: “Open Society Institute also provides space and other support services under the agreement”
  • Financial Integration: “$1,535,000 for services under the agreement, including $1,401,000 for salaries and benefits”
  • Outstanding Balances: “$547,000 due to Open Society Institute for services rendered under the agreement”

This comprehensive disclosure demonstrates that extensive operational integration can exist legitimately when properly documented and transparent to regulators.

Network Resource Distribution Patterns

Alliance for Open Society International’s 2023 Schedule I documents $180,000 in grants to Center for Popular Democracy (501(c)(3)) – the same organization that serves as “common paymaster” for political operations, demonstrating funding flows through the charitable network to support shared political infrastructure.

2023 Network Funding Documentation:

The Center for Popular Democracy network received $743,750 from multiple Open Society entities in 2023:

Center for Popular Democracy Resource Distribution Analysis

Center for Popular Democracy (501(c)(3)) grant distribution patterns raise questions about resource coordination:

  • $440,748 to Make the Road New York (501(c)(3)) for “Campaigns – Housing, States, Workers Justice” – documented funding for explicit campaign activities (Form 990, Schedule I, Line 6)
  • $474,500 to New York Communities for Change (501(c)(4)) – network expansion funding
  • (Form 990, Schedule I, Line 3)
  • $446,692 to Center for Popular Democracy Action Canvass Network LLC – corporate entity providing operational support
  • (Form 990, Schedule I, Line 5)
  • $50,000 to Working Families Organization Inc. (501(c)(4)) – direct political advocacy funding
  • (Form 990, Schedule I, Line 32)

The Resource Leverage Pattern

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 (2023 Center for Popular Democracy Form 990, Section VIII Line 1e and Schedule I). This pattern demonstrates resource coordination that appears difficult to reconcile with independent operations, where network funding enables the distribution of resources far exceeding direct government support.

Network Coordination Context: Center for Popular Democracy (501(c)(3)) provided a $440,748 grant to Make the Road New York (501(c)(3)) for “Campaigns – Housing, States, Workers Justice” (2023 Center for Popular Democracy Form 990, Schedule I). This creates documented funding flows: Center for Popular Democracy distributes government-subsidized resources to Make the Road New York for explicit “Campaigns” work, while Make the Road New York simultaneously receives $16.1 million in direct government funding and transfers $258,000 to political advocacy arms. This pattern represents one component of the broader coordination documented across the network.

Physical Infrastructure Integration

The physical infrastructure patterns raise questions about operational independence. Both Center for Popular Democracy (501(c)(3)) and Center for Popular Democracy Action Fund (501(c)(4)) operate from shared facilities at 449 Troutman Street, Suite A, Brooklyn, alongside other network entities including Make the Road Action Inc. (501(c)(4)) in Suite C, suggesting shared operational centers.

Physical Address Integration Evidence

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 Operations – 224 West 57th Street:

  • 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))
  • Foundation to Promote Open Society (501(c)(3))
  • Soros Economic Development Fund (501(c)(3))
  • Fund for Policy Reform Inc. (501(c)(4))
  • Fund for Policy Reform (501(c)(4))

Comprehensive Disclosure Standard: Alliance for Open Society International 2023 Schedule R explicitly lists all these entities as related organizations, demonstrating comprehensive relationship documentation that spans both charitable and political classifications under unified control at the same Manhattan address.

Compliance Framework Analysis

The convergence of evidence from multiple sources raises questions about compliance with several areas of federal tax law:

  • IRC Section 501(c)(3): Organizations must operate “exclusively” for exempt purposes, with strict limits on political campaign intervention.
  • IRC Section 6033: Organizations must accurately report relationships and transactions with related entities on their tax returns.
  • IRC Section 7206(1): Potential penalties for willful filing of false statements on federal tax returns.
  • IRC Section 4955: Potential excise tax penalties on political campaign intervention by tax-exempt organizations.
  • IRC Section 4958: Potential excess benefit transaction penalties for arrangements that may benefit disqualified persons.
Under the “substance over form” doctrine (Revenue Ruling 2007-41), the IRS examines operational reality rather than legal formalities when evaluating organizational independence. The documented evidence of reverse flows, combined with professional audit validation and comprehensive organizational admissions by some entities, provides substantial support for substance over form analysis while raising questions about disclosure consistency across the network.

The Cash Fungibility Principle in Practice

The scope of government funding flowing into this network raises questions about taxpayer money indirectly subsidizing political operations. The Center for Popular Democracy (501(c)(3)) example demonstrates how government grants may enable political activities by freeing up organizational resources. While receiving $545,202 in government grants in 2023, the organization distributed $1,411,940 throughout the network—259% of its government grant revenue—with the excess funded through other network sources, demonstrating financial integration patterns that raise questions about operational independence across entities claiming separate tax-exempt status.

Understanding Cash Fungibility

Money is interchangeable—even if organizations claim private donations fund political activities, the influx of millions in government grant money frees up other funds and operational capacity for political advocacy. This principle explains how taxpayer funds may indirectly subsidize political operations through sophisticated financial arrangements that raise questions about proper segregation of charitable and political activities.

The documentation reveals a network where some entities provide comprehensive transparency about extensive operational integration (Alliance for Open Society International, Open Society Institute) while others systematically avoid similar disclosures despite participating in similar arrangements. This contrast raises questions about whether disclosure practices are coordinated to maintain operational integration while obscuring the full scope of network relationships from regulatory oversight.

Part XI: Government Grant Recipients with Political Operations

Make the Road New York (501(c)(3)) demonstrates how government grants may enable political activities through what experts call the “cash fungibility principle.”

TOTAL GOVERNMENT FUNDING:

Simultaneous Political Transfers – AUDITOR VERIFIED:

This raises questions about oversight mechanisms when an organization receiving over $16 million in taxpayer funds simultaneously transfers resources to political advocacy arms within a network that demonstrates extensive coordination patterns.

Cross-Network Resource Flow Documentation

The coordination patterns become apparent when examining the $440,748 grant from Center for Popular Democracy (501(c)(3)) to Make the Road New York (501(c)(3)) specifically designated for “Campaigns – Housing, States, Workers Justice” (2023 Center for Popular Democracy Form 990, Schedule I). This creates documented evidence of how government funding may flow through the network:

The Resource Flow Pattern:

  • Step 1: Center for Popular Democracy (501(c)(3)) receives $545,202 in government grants
  • Step 2: Center for Popular Democracy distributes $1,411,940 throughout the network (259% of government grants)
  • Step 3: $440,748 flows directly to Make the Road New York for explicit “Campaigns” activities
  • Step 4: Make the Road New York simultaneously receives $16.1 million in government funding (52% of revenue)
  • Step 5: Make the Road New York transfers $258,000 to political advocacy arms

These documented flows raise questions about whether government funding indirectly enables political operations through resource fungibility that frees up other organizational capacity for political activities, despite claims of proper segregation between charitable and political functions.

Part XII: What This Evidence Pattern Reveals

Documented Coordination Analysis: The $34,414,598 in documented flows raises fundamental questions about operational coordination patterns that appear difficult to reconcile with claims of organizational independence. The patterns suggest systematic coordination that warrants investigation.

The Complete Flow Network Analysis: Our investigation documented patterns that raise questions about systematic coordination through a network system: George Soros → Foundation to Promote Open Society (501(c)(3)) $8.4 million → Tides Foundation (501(c)(3)) $29.3+ million → Tides Advocacy (501(c)(4)) + $4.6 million → Tides Center (501(c)(3)) → $343,753 → flows to Tides Advocacy (501(c)(4)) + $5.6 million → flows to Tides Foundation (501(c)(3)) + $325,000 → flows to Tides entities, creating patterns that raise questions about whether separate charitable and political operations exist or whether legal separation exists primarily for tax advantages.

The documented scope: $29,655,922 in total 501(c)(3) → 501(c)(4) flows ($29,312,169 from Tides Foundation + $343,753 from Tides Center) under identical “Healthy Individuals and Communities” program descriptions demonstrates patterns that raise questions about potential conversion of tax-deductible charitable donations into political advocacy operations.

Combined with disclosure inconsistencies (evidenced by contradictory schedules), shared personnel (evidenced by personnel overlap), and comprehensive organizational admissions by some entities contrasted with systematic concealment by others, this investigation provides substantial documentary evidence of coordination patterns that warrant examination to protect the integrity of the tax-exempt system.

The Compliance Framework Analysis

The patterns demonstrate sophisticated coordination across entities that claim independence while sharing leadership, facilities, and financial flows totaling over $34 million. The documentation reveals operational integration validated by professional auditors alongside systematic concealment of similar relationships by other network entities. This suggests potential coordination in disclosure practices designed to maintain operational integration while avoiding regulatory oversight requirements.

The sophistication of the arrangements raises questions about potential circumvention of tax law distinctions between charitable and political activities through concealed control structures that enable the conversion of charitable tax benefits into political coordination on an unprecedented scale.

IRS Whistleblower Complaint

We’ve filed an Enhanced Fifth Supplemental IRS whistleblower complaint documenting these coordination patterns with comprehensive evidence across three categories: disclosure inconsistencies on federal tax returns, concealed control relationships despite claims of independence, and documented flow patterns that raise questions about systematic coordination.

The complaint documents potential tax recovery exceeding $500 million, with patterns spanning potential false statement issues, political intervention concerns, and corporate income tax liability questions if exempt status is revoked across the syndicate’s $11+ billion in assets. The $34+ million coordination system documented in the organizations’ own tax filings provides the evidentiary foundation for this recovery analysis.

Conclusion

The documented evidence reveals patterns that raise serious questions about operational coordination disguised as charitable work. When organizations provide comprehensive relationship documentation in some contexts while systematically concealing similar relationships elsewhere, when professional auditors document operational integration, and when extensive coordination patterns occur while entities deny relationships, these patterns warrant investigation.

The Sophisticated Actor Framework: The Working Families Party’s 2022 documentation of their expertise in coordination requirements provides context that transforms coordination patterns from potential oversight to questions about willful conduct. Organizations that demonstrate sophisticated knowledge of regulatory frameworks and then engage in systematic concealment patterns raise questions about potential willful intent that warrant examination under IRC Section 7206(1) standards, though determination of criminal intent requires prosecutorial review.

The integrity of our tax system requires IRS examination when networks systematically avoid disclosure requirements while converting charitable tax benefits into political coordination through concealed control structures.

Independent charitable organizations typically don’t engage in $34+ million coordination flows while concealing key relationships. When they do, combined with disclosure inconsistencies on federal tax returns, concealed personnel control, professional audit validation of operational unity, and demonstrated knowledge of regulatory frameworks, these patterns raise questions about whether entities operate as components of a coordinated system rather than independent organizations deserving separate tax-exempt status.

The coordination flow documentation reveals patterns that raise questions about whether extensive charitable operations serve as mechanisms for converting tax-deductible donations into political coordination by sophisticated actors who demonstrably understood the regulatory framework they appear to be circumventing. The mathematics, professional auditor confirmation, organizational self-documentation of $34+ million in flows, and their own 2022 documentation of regulatory expertise create a comprehensive evidentiary record.

The question becomes whether the IRS will examine evidence that raises serious questions about systematic coordination patterns designed to circumvent the limitations that preserve the integrity of our tax-exempt system while maintaining the appearance of independent charitable operations.

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.

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