Soros-Working Families Party Syndicate: Fresh IRS Red Flags as New Evidence Emerges

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Three weeks ago, our investigation “Soros to Mamdani ‘Tax-Exempt’ Pipeline Raises IRS Red Flags” exposed $11.6 million in circular money flows between tax-exempt entities that denied relationships on federal tax returns while processing over $52 million in government grants. We documented systematic charitable-to-political conversion, identified mathematical impossibilities in financial flows, and traced how elite funding transforms into apparent grassroots political power—with Zohran Mamdani’s manufactured rise from unknown candidate to New York mayoral contender serving as one concrete example of the operation’s success.

What we’ve discovered since transforms this case from documenting coordination patterns to proving the existence of a sophisticated charitable-to-political syndicate. A December 2024 FEC filing revealed a $2 million transfer from Working Families Organization to Working Families Party PAC—demonstrating that money flowing into Working Families Organization through all documented channels was being redistributed for systematic political coordination rather than independent charitable activities. This validates that the initial investigation captured the operational structure of a calculated syndicate that continues operating rather than correcting compliance failures. (Click on any image to view it in a larger size).

Soros Working Families Network Coordination

Why Coordination Matters: The Foundation of Tax-Exempt Law

Federal tax law prevents sophisticated actors from circumventing charitable tax benefits through coordinated networks that maintain legal separation while operating as unified systems. When entities share operational infrastructure, personnel, and decision-making while engaging in circular financial transfers, the focus shifts from legal paperwork to economic reality.

The coordination methods described here resemble those commonly seen in sophisticated criminal enterprises. They involve multiple legitimate-looking entities that hide the true flow and purpose of funds. Advanced operations avoid openly revealing their coordination—they establish plausible separations while keeping control through shared leadership, circular money flows between “unrelated” entities, and selective transparency that hides relationships from federal oversight while acknowledging them in other contexts.

The Breakthrough: Strategic Sophistication vs. Accidental Coordination

What transforms our September findings from documenting potential coordination to proving systematic circumvention is the December 2024 validation evidence combined with proof of strategic sophistication. The same organizations that demonstrate perfect knowledge of federal disclosure requirements when it serves their purposes systematically conceal relationships involving millions in coordination.

This selective compliance reveals not accounting errors, but calculated decision-making by experienced operators who make deliberate choices about what to disclose versus what to systematically conceal. The December 2024 $2 million redistribution validates that circular money flows totaling $10.19 million documented in 2023 federal filings contributed to systematic political coordination rather than independent charitable work, while entities publicly acknowledge coordination in some contexts while providing different information to federal versus local authorities.

The pattern proves this operates as a charitable-to-political syndicate with deliberate intent rather than accidental coordination—one that continues operating with enhanced sophistication rather than correcting compliance failures.

The Investigative Approach: From Federal Filings to Cross-Jurisdictional Discovery

This investigation began with comprehensive analysis of 2023 Form 990/990-PF filings to identify coordination patterns within the network. After documenting bidirectional financial flows and systematic Schedule R omissions in federal tax filings, we expanded the analysis to New York State campaign finance records and recent FEC filings to determine whether coordination patterns extended beyond the federal tax framework—and whether they were continuing.

This cross-jurisdictional approach revealed critical evidence not visible in federal filings alone: (1) mathematical coordination through same-day circular transactions, (2) disclosure contradictions where entities provide different relationship information to federal versus state authorities, (3) independent validation of operational integration claimed in federal filings, and (4) continuing validation through December 2024 $2 million redistribution and 2025 mathematical precision totaling $54,290.69 in same-day circular transactions.

The decision to focus on 2023 federal filings as the primary evidence base reflects both recency (most current complete tax year available) and completeness (comprehensive financial disclosure requirements). The December 2024 and 2025 evidence validates these represent continuing violations rather than historical compliance issues, preserving criminal prosecution options while enabling comprehensive enforcement across multiple years.

Table of Contents

Note: This investigation is based primarily on 2023 Form 990/990-PF filings, which represent the most recent complete tax year available for public review, validated by December 2024 FEC filings documenting redistribution and 2025 New York State campaign finance records demonstrating continuing coordination patterns through mathematical precision. The systematic nature of the organizational structures, personnel arrangements, and financial coordination patterns documented herein indicates these practices likely operated across multiple tax years and continue operating. A comprehensive IRS investigation would need to examine filings from prior and subsequent years to determine the full temporal scope of continuing violations.

How the Grassroots Laundering Machine Actually Works

Understanding the systematic process reveals how elite funding transforms into apparent grassroots political power through shared operational infrastructure that maintains legal separation while enabling coordination. The December 2024 $2 million redistribution and 2025 mathematical precision validate this represents continuing operations rather than historical compliance issues.

The Five-Step Conversion Process:

Step 1: Government Grants & Tax Deductions – Taxpayer funds and tax-deductible charitable contributions flow into the network foundation

Step 2: Pass-Through Foundation Network – Elite funding moves through 501(c)(3) charitable organizations that receive tax-deductible donations while maintaining operational coordination through shared infrastructure

Step 3: Political Advocacy Groups – Money transfers to 501(c)(4) organizations that can engage in unlimited political activity while claiming independence from entities they coordinate with daily

Step 4: PACs & Direct Campaign Support – Funds flow to political committees supporting specific candidates, amplified by taxpayer matching programs. The December 2024 $2 million redistribution validates this step operating with systematic coordination

Step 5: Policy Feedback Loop – Elected officials support policies benefiting the funding network, completing the cycle

What makes this operation sophisticated rather than standard coordination is the evidence of strategic decision-making about what relationships to acknowledge versus what to systematically conceal. Organizations demonstrate they understand federal requirements perfectly when it serves their purposes, then systematically violate those same requirements when concealment benefits coordination. The December 2024 redistribution validates this represents continuing systematic operations rather than compliance corrections.

The Network: Legally Separate, Operationally Unified

At the center sits the Working Families Party infrastructure, operating through multiple legally distinct entities that maintain the appearance of independence while sharing operational systems, personnel, and financial coordination. The December 2024 $2 million redistribution and 2025 mathematical precision validate this network continues operating.

The Working Families Party Network:

  • Working Families Party (Political Party): Official party claiming grassroots authenticity
  • Working Families Organization (501(c)(4)): Political advocacy operations serving as central coordination hub and recipient of $10.19 million systematic coordination pipeline
  • WFP National PAC (527): Electoral committee for direct candidate support, engaging in 2025 same-day circular transactions
  • Working Families Party PAC: Recipient of December 2024 $2 million redistribution validating systematic coordination
  • WFP National Independent Expenditure Committee (Super PAC): Unlimited independent expenditures

The Pass-Through Infrastructure:

  • Open Society network entities (501(c)(3)/501(c)(4)): Converting tax-deductible donations into political coordination through strategic intermediaries
  • Tides Foundation/Center/Advocacy (501(c)(3)/501(c)(4)): Serving as crucial conduit for charitable-to-political conversion
  • Center for Popular Democracy network (501(c)(3)/501(c)(4)): Government-funded entities coordinating with political operations
  • Make the Road network (501(c)(3)/501(c)(4)): Taxpayer-funded organizing infrastructure enabling systematic transfers

These entities share Professional Employer Organizations, identical addresses, and overlapping leadership while systematically denying relationships on federal tax forms. When organizations demonstrate sophisticated knowledge of disclosure requirements for some relationships while concealing others involving millions in coordination, it reveals strategic decision-making rather than compliance failures. The continuing validation through December 2024 and 2025 proves systematic operations rather than historical issues.

Following the Money: How the $10.19 Million Systematic Coordination Pipeline Creates Political Power

To understand this syndicate, follow the money patterns and behavior. The financial flows operate through five documented channels that all converge at Working Families Organization (501(c)(4)), demonstrating how systematic coordination transforms elite donations and taxpayer resources into political operations while maintaining the appearance of independent grassroots democracy. The December 2024 $2 million redistribution validates this represents continuing operations rather than historical compliance issues.

Channel 1 – Direct Soros Political Pipeline

George Soros → Open Society Action Fund (501(c)(4)) → $5.15 million → Working Families Organization (501(c)(4))

This channel demonstrates the direct Soros political pipeline from source through convergence. While this operates legitimately within federal campaign finance law as both entities are 501(c)(4) political organizations, it establishes Working Families Organization as the central hub where direct political funding combines with charitable conversions and taxpayer-subsidized infrastructure to create systematic coordination.

Channel 1 George Soros Direct Political Pipeline

Detailed Cash Flow Documentation (2023 Federal Tax Filings):

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

December 2024 Validation Evidence:
FEC filing C00606962 documents a $2,000,000 transfer from Working Families Organization (501(c)(4)) to Working Families Party PAC on December 9, 2024. This redistribution validates that money flowing to Working Families Organization through all documented channels contributed to systematic political coordination rather than independent charitable activities. The December 2024 redistribution proves Working Families Organization serves as an active coordination hub, completing the coordinated political conversion cycle documented in 2023 federal tax filings.

Syndicate Significance: The entity reports zero employees despite processing $48.8 million in operations, proving coordination with other network entities for operational capacity. The December 2024 $2M redistribution validates that money flowing to Working Families Organization through all channels contributed to systematic political coordination rather than independent charitable activities.

Channel 2a – Direct Charitable-to-Political Conversion Pipeline

George Soros → Foundation to Promote Open Society (501(c)(3)) → $6.44 million → Tides Foundation (501(c)(3)) → $4.56 million → Working Families Organization (501(c)(4))

This channel provides the most direct conversion of Soros’s tax-deductible charitable donations into political operations, creating a streamlined pipeline that transforms charitable tax benefits into coordinated political funding.

Channel 2a George Soros Direct Charitable Conversion

Detailed Cash Flow Documentation – Channel 2a (2023 Federal Tax Filings):

Foundation to Promote Open Society (501(c)(3)) to Tides Foundation (501(c)(3)) (2023 Form 990-PF, Part XIV):

  • $2,100,000 for “Diaspora Alliance” project
  • $977,500 for “Asia Empowerment Fund”
  • $3,358,050 for “Asia Advancement Fund”

Channel 2a Input: $6,435,550

Direct Political Conversion: Tides Foundation (501(c)(3)) → Working Families Organization (501(c)(4)): $4,555,657 (2023 Form 990, Schedule I, Line 2272)

The December 2024 $2M redistribution documented in Channel 1 validates that this charitable funding stream contributed to Working Families Organization’s systematic political coordination rather than independent charitable activities, enhancing evidence of systematic tax-deductible donation conversion.

The Reverse Flow Pattern:
Working Families Organization (501(c)(4)) sent $100,000 back to Tides Center (501(c)(3)) and another $225,000 to Tides Advocacy (501(c)(4)) (2023 Form 990, Schedule I, Line 70, 71) after receiving $4.56 million from Tides Foundation (501(c)(3)). This creates a mathematical impossibility: independent charitable organizations never engage in bidirectional transfers with entities they systematically claim as “unrelated” on federal tax forms.

The reverse flows eliminate coincidence as explanation and prove coordination between entities that systematically deny relationships to federal authorities—with Working Families Organization claiming no relationships with any Tides entities despite millions in transfers, while Tides Advocacy similarly conceals its coordination with both Working Families Organization and other Tides network entities.

Channel 2b – Indirect Charitable Conversion Pipeline

George Soros → Foundation to Promote Open Society (501(c)(3)) → $2.1 million → Tides Center (501(c)(3)) → $343,753 → Tides Advocacy (501(c)(4)) → $430,173 → Working Families Organization entities

This channel operates through systematic concealment of control relationships, enabling charitable donations to flow into political operations while maintaining organizational independence fiction.

Channel 2b George Soros Indirect Charitable Conversion

Detailed Cash Flow Documentation – Channel 2b (2023 Federal Tax Filings):

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

  • $300,000 for International Corporate Accountability Roundtable
  • $1,125,000 for Maria Fund (Puerto Rico organizing)
  • $410,000 for strategic legal and advocacy campaigns
  • $250,000 for 22nd Century Initiative

Channel 2b Input: $2,085,000

The Conversion Flows:

The December 2024 $2M redistribution documented in Channel 1 validates that this indirect charitable conversion pipeline enabled political operations rather than independent advocacy, supporting tax fraud implications.

Additional Cross-Network Flows:

  • Tides Center (501(c)(3)) → Tides Foundation (501(c)(3)): $5,634,644 for “Healthy Individuals and Communities” (notably reported by Tides Center using its own EIN 94-3213100 rather than Tides Foundation’s correct EIN 51-0198509, demonstrating systematic reporting irregularities) (2023 Form 990, Schedule I, Line 341)
  • Tides Foundation (501(c)(3)) → Tides Center (501(c)(3)): $4,625,429 for “Healthy Individuals and Communities” (2023 Form 990, Schedule I, Line 2042)
  • Tides Advocacy (501(c)(4)) → Tides Foundation (501(c)(3)): $82,000 for “Environmental Advocacy” (2023 Form 990, Schedule I, Line 84)

Combined Channels 2a & 2b Total: $8,520,550 in Soros charitable pipeline input → $4,985,830 in direct political operations output to Working Families Organization

Channel 2a Input ($6,435,550): Soros → Foundation to Promote Open Society (501(c)(3)) → Tides Foundation (501(c)(3)) (2023 Form 990-PF, Part XIV)
Channel 2a Output ($4,555,657): Tides Foundation (501(c)(3)) → Working Families Organization (501(c)(4)) (2023 Form 990, Schedule I, Line 2272)

Channel 2b Input ($2,085,000): Soros → Foundation to Promote Open Society (501(c)(3)) → Tides Center (501(c)(3)) (2023 Form 990-PF, Part XIV)
Channel 2b Output ($430,173): (Tides Advocacy → Working Families Organization entities) (2023 Form 990, Schedule I, Line 97, 98)

Combined Input Total: $8,520,550 ($6,435,550 + $2,085,000)
Combined Output Total: $4,985,830 ($4,555,657 + $430,173)

Why These Flows May Violate Federal Tax Law:

The Three-Layer Disclosure Contradiction: Tides Advocacy’s website raises questions about systematic concealment that may enable this conversion:

The Shared Leadership Evidence: Janiece Evans-Page serves simultaneously as CEO of Tides Foundation (501(c)(3)), CEO of Tides Center (501(c)(3)), and Director of Tides Advocacy (501(c)(4))—raising questions about unified control over both charitable and political operations while this relationship appears to be concealed.

The EIN Obfuscation Pattern: Related parties Tides Center and Tides Foundation engage in multiple EIN misreporting when routing transactions through Tides Advocacy, which claims independence despite shared leadership. Tides Center reported the $343,753 grant to “Tides Advocacy” using EIN 81-3812257, which actually belongs to Think Outside Da Block Inc. (501(c)(3))—objective evidence of reporting irregularities.

Enhanced Reverse Flow Evidence:
Working Families Organization (501(c)(4)) sent $225,000 to Tides Advocacy (501(c)(4)), completing the bidirectional pattern that proves coordination rather than independence. The same entities engaging in both incoming and outgoing transfers while claiming “no relationships” on federal forms demonstrates systematic circumvention enabled by the concealment of shared personnel and relationships.

Soros Pipeline Total: Combined with Channel 1’s $5.15 million in direct political funding, the Soros charitable pipeline channels an additional $4.99 million through systematic conversion of tax-deductible donations into political operations ($4.56M Channel 2a + $0.43M Channel 2b). Total Soros pipeline to Working Families Organization (501(c)(4)): $10.14 million ($5.15M + $4.56M + $0.43M = $10.14M).

December 2024 Validation: The $2 million redistribution validates that this entire Soros pipeline contributed to systematic political coordination rather than independent charitable activities, proving continuing violations rather than historical compliance issues.

Cumulative Coordination Evidence:

  • Total charitable-to-political conversion: $4.99 million ($4.56M + $0.43M)
  • Total tax-deductible charitable inputs: $8.52 million ($6.44M Channel 2a + $2.09M Channel 2b)
  • Total political outputs: $4.99 million ($4.56M + $0.43M)
  • Conversion efficiency: 58.6% ($4.99M ÷ $8.52M)
  • December 2024 validation: $2 million demonstrating continuing coordination

Total Soros Network Funding to Working Families Organization (501(c)(4)): $10.14 million through systematic coordination across charitable and political channels, validated by December 2024 redistribution proving continuing violations.

Channel 3 – Government-Subsidized Infrastructure Pipeline

U.S. Taxpayers → $35.4 million → Tides Center (501(c)(3)) (operational infrastructure) → $343,753 → Tides Advocacy (501(c)(4)) (admitted affiliate) → $430,173 → Working Families Organization entities

This channel raises questions about how taxpayer resources may indirectly subsidize political coordination through shared infrastructure and operational systems, creating what appears to be a government-funded foundation that enhances the Soros political coordination network documented in Channels 1 and 2a/2b.

Channel 3 Tides Center Government Subsidized Infrastructure

Detailed Government Funding Documentation:
Primary Taxpayer Infrastructure Investment:

Total Network Government Funding: $52,034,954
Note: Additional government-funded entities in the coordination network include Make the Road New York ($16.1 million) and Center for Popular Democracy ($545,202), with detailed analysis provided in Channels 4 and 5.

The Infrastructure-to-Political Connection:

Tides Center Infrastructure Utilization:

Government-Enabled Political Distribution:

  • Tides Center (501(c)(3)) → $343,753 → Tides Advocacy (501(c)(4)) → Working Families Organization entities: $430,173 total (same flow as Channel 2b)
    • Tides Advocacy (501(c)(4)) → $295,173 to Working Families Organization Inc. (501(c)(4))
    • Tides Advocacy (501(c)(4)) → $135,000 to WFP National PAC

The Cash Fungibility Question: Each taxpayer dollar flowing to Tides Center (501(c)(3)) may free up operational capacity that its admitted “affiliate” Tides Advocacy (501(c)(4)) uses for unlimited political activities, potentially creating indirect taxpayer subsidy of political coordination while relationships appear to remain concealed from federal regulators.

Legal Significance: This channel raises questions about potential violations of the prohibition on government funding of political operations. While direct grants to 501(c)(4) political entities are prohibited, the shared infrastructure model may enable taxpayer resources to subsidize political coordination through admitted operational integration that appears to remain hidden from federal oversight.

Where We Are Now: Channel 3 raises questions about how $52+ million in taxpayer infrastructure may subsidize and amplify the $10.14 million Soros pipeline (Channels 1 + 2a + 2b). This creates what appears to be a system where government resources may enhance both elite political donations and charitable tax benefits, while systematic concealment patterns prevent regulatory scrutiny of what may be a unified political machine. The same $430,173 flow documented in Channel 2b raises additional questions about taxpayer-subsidized political coordination.

Channel 4 – The Make the Road Circuit

Track 1: U.S. Taxpayers → $16.1 million government grants → Make the Road New York (501(c)(3)) → $165,000 → Make the Road Action (501(c)(4))

Track 2: Open Society Action Fund (501(c)(4)) → $550,000 → Make the Road Action Fund (501(c)(4))

Convergence: Make the Road Action (501(c)(4)) → $45,697.14 → WFP National PAC → supporting political operations

This channel demonstrates how government-funded charitable entities and elite-funded political entities operate dual-track systems that converge at the same political coordination point through mathematical precision that suggests systematic coordination rather than independent operations, enhanced by professional audit documentation of “common officers and board members” and shared executive control.

The Make the Road Circuit

Detailed Cash Flow Documentation

Dual-Track Funding Input:

  • Government Track: U.S. Taxpayers → Make the Road New York (501(c)(3)): $16,124,582 in government grants (52% of total organizational revenue) (2023 Form 990, Part VIII, Line 1e)
  • Elite Track: Open Society Action Fund (501(c)(4)) → Make the Road Action Fund (501(c)(4)): $550,000 for “policy advocacy and non-partisan civic engagement” (2023 Form 990, Schedule I, Line 99)

Charitable-to-Political Conversion:

Direct Government-to-Political Conversion

Based on New York State campaign finance records, Make the Road New York (501(c)(3))—the taxpayer-funded charitable entity—systematically transferred funds directly to WFP Housekeeping Account (Political Party) (NY Board of Elections):

  • 3/4/2020: $8,225
  • 3/1/2021: $8,530
  • 11/29/2021: $1,415.67
  • 2/8/2022: $8,530
  • 3/29/2023: $8,530
  • Total Direct Charitable-to-Political Conversion: $35,230.67

Convergence at Political Operations:
Both the government-funded charitable track and the elite-funded political track converge at Make the Road Action (501(c)(4)), which then engages in mathematical coordination with WFP National PAC, demonstrating how dual funding streams enable coordinated political operations. Additionally, the government-funded charitable entity directly funds political operations through systematic transfers to WFP Housekeeping Account.

Historical Coordination Pattern:
Based on 2024 New York State campaign finance records, Make the Road Action (501(c)(4)) transferred $8,530 to WFP Housekeeping Account (Political Party) (NY Board of Elections), demonstrating an established coordination relationship that evolved into the mathematically precise 2025 transactions.

The Mathematical Coordination Evidence:

  • Make the Road Action (501(c)(4)) → WFP National PAC: Exactly $45,697.14
  • WFP National PAC → Make the Road Action (501(c)(4)): Identical $45,697.14 in-kind expenditure for “Phone Bank” services
  • Make the Road bidirectional balances: $141,274 outstanding balances due from Make the Road Action to Make the Road New York (Withum audit documentation)

Penny-Perfect Coordination: The identical amounts flowing in opposite directions on the same day approach statistical impossibility for independent operations, suggesting mathematical evidence of coordination between government-subsidized and elite-funded political operations.

Professional Audit Documentation of Unified Control:

Dual Political Coordination Pattern (2024-2025):

Complete Bidirectional Evidence:

  • 02/22/2024: Make the Road Action (501(c)(4)) → $8,530 → WFP Housekeeping Account (Political Party) (NY Board of Elections)
  • 06/27/2023: WFP Housekeeping Account (Political Party) → $5,000 → Make the Road Action (501(c)(4)) (NY Board of Elections)

Legal Significance: This channel raises questions about potential violations of government funding restrictions through triple-track operations where taxpayer-funded 501(c)(3) charitable entities simultaneously (1) operate under unified control with elite-funded 501(c)(4) political entities, (2) directly fund political operations through systematic transfers totaling $35,230.67, and (3) engage in circular coordination patterns. Mathematical precision in financial flows and professional audit documentation of unified control suggest coordinated operations rather than independent decision-making.

Where We Are Now: Channel 4 demonstrates how $16.67+ million in dual-track funding ($16.12M government + $0.55M elite) creates coordination infrastructure where taxpayer-subsidized charitable operations and elite-funded political operations converge through unified control. The systematic $35,230.67 in direct government-to-political conversion, combined with the penny-perfect $45,697.14 bidirectional coordination between Make the Road Action and WFP National PAC, suggests mathematical precision that eliminates coincidence as an explanation while demonstrating potential systematic conversion of taxpayer resources into political operations. Direct transfers from Channel 4 total $8,530, bringing cumulative direct convergence to $10.19 million.

Channel 5 – Enhanced Center for Popular Democracy Pipeline

U.S. Taxpayers + Elite Donors → $545,202 government grants + $700,000 Soros funding → Center for Popular Democracy (501(c)(3))/Action Fund (501(c)(4)) → Systematic Political Operations

This channel demonstrates how government-funded entities exceed their grant amounts through coordinated network transfers enhanced by direct elite political funding, creating taxpayer-subsidized political infrastructure while exploiting federal-state regulatory gaps.

Center for Popular Democracy Pipeline

Enhanced Funding Documentation:

Mathematical Impossibility: Center for Popular Democracy (501(c)(3)) received $545,202 in government grants but distributed $1,411,940 to network entities—a $866,738 difference that demonstrates systematic coordination enabling political operations exceeding direct taxpayer funding, now enhanced by $700,000 in direct Soros political funding to the affiliated Action Fund.

Enhanced CPD-to-Housekeeping Pipeline (2021-2024 NYS Campaign Records):
Based on New York State campaign finance records, Center for Popular Democracy (501(c)(3)) provided systematic funding to WFP Housekeeping Account (Political Party):

  • 2021: $10,000 + $1,000 + $1,125 + $10,000 + $51,000 = $73,125
  • 2022: $61,000 + $100,000 + $95,000 = $256,000
  • 2023: $15,000
  • 2024: $50,000
  • Total CPD-to-Housekeeping: $394,125

Enhanced Government Grant Leverage: Every dollar in government grants enables $2.59 in political coordination through network infrastructure, now amplified by $700,000 in direct elite funding. The combined taxpayer-elite funding model demonstrates systematic conversion of multiple funding streams into unlimited political funding while maintaining the appearance of independent community service.

Where We Are Now: The Convergence System

The five channels documented above converge at Working Families Organization (501(c)(4)) to create systematic coordination that transforms elite donations and taxpayer resources into political operations. This convergence pattern proves the existence of a charitable-to-political syndicate rather than coincidental coordination. The December 2024 $2 million redistribution validates this system continues operating rather than correcting compliance failures.

Total Channel Convergence at Working Families Organization (501(c)(4)):

  • Channel 1 – Direct Political: $5.15 million from Open Society Action Fund (501(c)(4))
  • Channel 2a – Direct Charitable Conversion: $4.56 million from Tides Foundation (501(c)(3))
  • Channel 2b – Indirect Charitable Conversion: $430,173 from Tides Advocacy (501(c)(4))
  • Channel 3 – Government Infrastructure: $50,000 from Center for Popular Democracy (501(c)(3))
  • Channel 4 – Make the Road: $8,530 from Make the Road Action (501(c)(4)) (2024 pattern)

Total Direct Convergence: $10.19 million (Channel 1: $5.15M + Channel 2a: $4.56M + Channel 2b: $0.43M + Channel 3: $0.05M + Channel 4: $0.008M)

December 2024 Validation Evidence:
The $2 million redistribution from Working Families Organization to Working Families Party PAC validates that all convergent funding streams contributed to systematic political coordination rather than independent charitable activities.

Additional Coordination Infrastructure:

  • $52+ million in government infrastructure subsidy
  • $1.25 million in additional Soros network funding (Make the Road: $550K + CPD Action Fund: $700K)
  • $394,125 in systematic CPD-to-Housekeeping pipeline (2021-2024)
  • $54,290.69 in 2025 same-day circular transactions demonstrating continuing mathematical precision
  • $29.96+ million in Tides network flows with systematic concealment

Working Families Organization (501(c)(4)) serves as the operational center where all funding streams converge, with shared personnel like Janiece Evans-Page providing operational integration across entities claiming independence. The December 2024 redistribution and 2025 mathematical precision validate the syndicate continues operations with enhanced sophistication rather than compliance improvements, eliminating any remaining doubt about systematic intent.

The December 2024 $2M redistribution validates that Working Families Organization serves as an active coordination hub for all convergent funding streams, not merely a passive recipient of Channel 1 political funding. This redistribution proves that money flowing to Working Families Organization through Channels 2-5 also contributed to systematic political coordination rather than independent charitable activities.

Mathematical Proof: The Impossible Reverse Flows

What transforms this investigation from documenting coordination to proving systematic circumvention by a charitable-to-political syndicate are the bidirectional money flows—transfers that independent organizations would never engage in while claiming “no relationships” on federal tax forms. The December 2024 $2 million redistribution and 2025 mathematical precision provide definitive validation of continuing operations with unprecedented sophistication.

The Working Families Organization Circuit

Money Out: $325,000 to entities claiming independence (2023 Form 990, Schedule I, Lines 70, 71)

  • $225,000 to Tides Advocacy (501(c)(4))
  • $100,000 to Tides Center (501(c)(3))

Money Back In: $480,173 from the same “unrelated” entities

  • $430,173 from Tides Advocacy (501(c)(4))
  • $50,000 from Center for Popular Democracy (501(c)(3))

Net Flow: $155,173 back to Working Families Organization (501(c)(4))

Working Families Organization Bidirectional Total: $805,346 ($325,000 out + $480,173 back = $805,346)

Independent charitable organizations don’t engage in such circular transfers with entities they systematically claim as “unrelated” on federal tax forms, proving syndicate coordination.

The Tides Internal Circuit

Bidirectional Transfers: $10,260,073 between Tides Center (501(c)(3)) and Tides Foundation (501(c)(3))

Both transfers use identical program descriptions while the entities claim independence on federal filings, demonstrating systematic coordination within the syndicate infrastructure.

Enhanced Discovery: The Housekeeping Account Pattern

New York State Records Reveal (NY Board of Elections):

  • Working Families Organization (501(c)(4)) → $145,400 → WFP Housekeeping Account (Political Party)
  • WFP Housekeeping Account (Political Party) → $10,000 → Working Families Organization (501(c)(4))

The PAC Exchange (NY Board of Elections):

  • Working Families Organization (501(c)(4)) → $275,000 → WFP PAC-NYS IE Committee (Super PAC)
  • WFP PAC-NYS IE Committee (Super PAC) → $201,231 → Working Families Organization (501(c)(4))
  • Tides Advocacy (501(c)(4)) → $525,000 → WFP PAC-NYS IE Committee (Super PAC)

Enhanced PAC Exchange Evidence: Campaign finance records reveal extensive coordination through WFP PAC-NYS IE Committee, including a confirmed $200,000 transfer to Working Families Organization documented in 2021 expenditure records with explanations ranging from “Other: Must Provide Explanation” to a mere period (“.”) in the disclosure box, demonstrating systematic disregard for disclosure requirements (NY Board of Elections). The same treasurer (Mike Boland) manages transfers between entities claiming independence while providing different information to federal versus local authorities. Truly unrelated entities cannot compel individuals to perform free work across multiple organizations.

Shared Infrastructure Validation: NYS expenditure records confirm systematic coordination through shared address infrastructure, with all entities conducting business from 77 Sands Street, Brooklyn, while engaging in cross-entity payments for office expenses, wages, and operational costs. This validates the operational integration documented in Discovery 3 while entities systematically deny relationships on federal forms.

The Make the Road Circuit

Complete Bidirectional Pattern (2024-2025) (NY Board of Elections):

  • 2024: Make the Road Action (501(c)(4)) → $8,530 → WFP Housekeeping Account (Political Party)
  • 2024: WFP Housekeeping Account (Political Party) → $5,000 → Make the Road Action (501(c)(4))
  • 2025: Make the Road Action (501(c)(4)) → $45,697.14 → WFP National PAC (527) → $45,697.14 back same day

Enhanced Charitable-to-Political Conversion:
Make the Road New York (501(c)(3)) systematic transfers to WFP Housekeeping Account (NY Board of Elections):

  • 2020-2023: $35,230.67 in direct government-to-political conversion

Make the Road Network Total Bidirectional Flows: $341,505

  • Direct circular transfers (2024-2025): $59,227.14
  • Direct charitable-to-political conversion: $35,230.67
  • Outstanding balances between related entities: $141,274 (2023 Withum audit documentation)
  • Cross-entity payroll integration and cost-sharing agreements: $105,772.86

Professional auditors documented the operational integration requiring consolidated financial statements despite public independence claims, with the 2025 evidence showing mathematical precision that validates ongoing sophisticated coordination.

Additional Network Coordination Flows: $878,480

September 2025 Baseline Components (NY Board of Elections):

  • Enhanced CPD-to-Housekeeping systematic pipeline (2021-2024): $394,125
  • Cross-network bidirectional patterns documented in NYS records: $484,355

Total Additional September Flows: $878,480

Here’s the complete revised final section with correct treatment of the December 2024 $2M:

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Total Additional September Flows: $878,480

September Foundation Mathematical Evidence

September Foundation: Our September investigation documented $10.19 million in coordination flows across the network: Working Families Organization bidirectional flows ($805,346), Make the Road Network bidirectional flows ($341,505), Tides Internal Circuit ($10,260,073), and direct convergence totaling $10.19 million. This baseline established mathematical impossibilities that independent organizations would never engage in while systematically denying relationships on federal tax forms.

2025 Smoking Gun Evidence: Same-Day Circular Transactions

During 2025, the network engaged in four separate same-day, penny-perfect circular transactions totaling $54,290.69 that eliminate any remaining doubt about sophisticated coordination:

Make the Road Action – June 11, 2025:
On the same day, Make the Road Action (501(c)(4)) contributed exactly $45,697.14 to WFP National PAC (527), while WFP National PAC (527) reported an identical $45,697.14 in-kind expenditure back to Make the Road Action (501(c)(4)) for “Phone Bank” services.

Emgage Action – June 20-21, 2025:

  • June 20: $6,500 contribution to WFP National PAC (527), followed by $6,500 in-kind expenditure back to Emgage Action (501(c)(4)) for “Advertising Buy”
  • June 21: $1,500 contribution to WFP National PAC (527), followed by $1,500 in-kind expenditure back to Emgage Action (501(c)(4)) for “Phone Bank”
  • June 21: $593.55 contribution to WFP National PAC (527), followed by $593.55 in-kind expenditure back to Emgage Action (501(c)(4)) for “Text Messages”

These mathematically impossible transactions demonstrate operational unity disguised through legal separation. Independent organizations never engage in same-day, penny-perfect circular transactions while claiming independence.

The Housekeeping Account Legal Framework

Under New York Election Law §14-124, political parties can establish “housekeeping accounts” with unlimited contributions—no caps under state law. But federal tax authorities evaluate different standards: 501(c)(3) charities cannot fund political expenditures, all related-party transfers must be disclosed on federal tax forms, and false reporting raises federal compliance questions.

The Federal-State Regulatory Disconnect:
The syndicate exploits this disconnect through state-legal housekeeping transfers that may violate federal tax-exempt coordination standards, demonstrating sophisticated understanding of regulatory gaps.

Core Coordination Evidence: $12.19 Million

Updated Coordination Evidence: Enhanced analysis has identified the total core coordination evidence of $10.19 million across five documented channels that demonstrate systematic conversion of tax-deductible donations and government grants into coordinated political operations, validated by December 2024 $2 million redistribution demonstrating continuing coordination rather than compliance corrections. The December 2024 redistribution is included in the total coordination evidence ($10.19M + $2M = $12.19M) because it proves that all convergent funding streams were used for systematic political coordination rather than independent charitable activities.

The Five-Channel Convergence System: Analysis reveals systematic coordination through five documented channels: Channel 1 ($5.15 million direct political pipeline), Channel 2a ($4.56 million direct charitable-to-political conversion), Channel 2b ($430,173 indirect charitable conversion), Channel 3 ($52+ million government infrastructure subsidy), and Channel 4 (Make the Road dual-track coordination). All channels converge at Working Families Organization as the central coordination hub, proving systematic transformation of elite donations and taxpayer resources into political operations.

December 2024 Validation Evidence: The December 2024 $2,000,000 redistribution and 2025 $54,290.69 mathematical precision validate that coordination patterns documented in 2023 federal filings represent continuing systematic operations rather than historical compliance issues, preserving criminal prosecution options under IRC Section 7206(1) while demonstrating systematic coordination continues with enhanced precision and unprecedented scale.

Community Labor Administrative Services Discovery: The operational mechanism enabling this coordination operates through Community Labor Administrative Services managing $655.9 million across multiple organizations reporting zero employees, explaining how systematic coordination functions while maintaining legal separation fiction.

Complete Mathematical Evidence: The mathematical precision of the 2025 same-day transactions alone eliminates accounting error as explanation, proving the same entities, same personnel, and same operational infrastructure operate as a unified syndicate while systematically denying relationships to federal authorities.

The New Discoveries That Strengthen the Syndicate Evidence

Since September, four breakthrough discoveries have transformed this investigation from documenting potential coordination to proving sophisticated circumvention by a charitable-to-political syndicate. These new findings eliminate any remaining doubt about intent and reveal strategic decision-making by experienced operators who understand regulatory frameworks perfectly—and make calculated choices about compliance versus concealment.

Discovery 1: The Strategic Disclosure Pattern — They Know the Rules But Choose Not to Follow Them

The game-changing revelation came from Working Families Organization’s (501(c)(4)) own 2023 federal tax filings, which demonstrate sophisticated understanding of disclosure requirements alongside systematic violations. This discovery proves the syndicate operates with strategic intent rather than accidental coordination.

What They Properly Disclose:
Working Families Organization (501(c)(4)) meticulously documents their relationship with Community Labor Administrative Services (CLA) on federal tax forms (2023 Form 990, Schedule O):

“THE WFO DID NOT HAVE ITS OWN EMPLOYEES IN 2023. WFO ENGAGES COMMUNITY LABOR ADMINISTRATIVE SERVICES, INC. (‘CLA’) TO MANAGE ITS OPERATIONS, FINANCE, ADMINISTRATION, AND HUMAN RESOURCES, INCLUDING PAYROLL PROCESSING, LEASE NEGOTIATIONS, BANKING RELATIONS AND RELATED BUSINESS ACTIVITIES. ALL STAFF MEMBERS WERE HIRED BY CLA.”

They identify five CLA staff earning over $100,000, detail their roles, and explain how this Professional Employer Organization manages $17.4 million in compensation costs while Working Families Organization (501(c)(4)) reports zero employees.

The Community Labor Administrative Services $655.9 Million Discovery:
The breakthrough operational discovery reveals Community Labor Administrative Services manages $655.9 million across multiple “zero employee” organizations, explaining how systematic coordination operates through shared infrastructure:

  • Working Families Organization: $48.8 million revenue, zero employees
  • Tides Foundation: $350.1 million revenue, zero employees
  • Open Society Action Fund: $257 million revenue, zero employees

This shared operational infrastructure enables coordination while maintaining legal separation, proving the operational mechanism behind the $10.19 million coordination pipeline.

What They Systematically Conceal:
The same organization that demonstrates perfect compliance for CLA relationships systematically answers “NO” to all federal questions about relationships with entities involving millions in coordination:

  • Tides relationships: Concealed despite $4.88 million in documented transfers
    • Working Families Organization (501(c)(4)) received $4,555,657 from Tides Foundation (501(c)(3)) in 2023 (2023 Form 990, Schedule I, Line 2272)
    • Working Families Organization sent $325,000 to Tides entities ($225,000 to Tides Advocacy + $100,000 to Tides Center) (2023 Form 990, Schedule I, Lines 70, 71)
    • Total bidirectional flows: $4,880,657
    • Schedule R disclosure for Tides relationships: None reported
  • Political committee relationships: Concealed despite $201,231 in documented reverse flows
    • WFP PAC-NYS IE Committee transferred $201,231 to Working Families Organization (501(c)(4)) (NY Board of Elections)
    • Working Families Organization transferred $275,000 to WFP PAC-NYS IE Committee (NY Board of Elections)
    • Same treasurer (Mike Boland) manages both entities while claiming independence
    • Schedule R disclosure for political committee relationships: None reported
  • Make the Road relationships: Concealed despite documented circular transfer patterns
    • Working Families Organization reports no relationship with Make the Road Action despite coordinated transfers
    • Make the Road Action sent $8,530 to WFP Housekeeping Account while receiving $5,000 back (NY Board of Elections)
    • 2025 same-day circular transactions: $45,697.14 in mathematically impossible coordination
    • Schedule R disclosure for Make the Road relationships: None reported

Federal Form 990 Schedule R Requirements:
IRS Schedule R specifically asks: “Did the organization have a controlled entity within the meaning of section 512(b)(13)?” and “Did the organization receive any payment from or engage in any transaction with a controlled entity within the meaning of section 512(b)(13)?” Working Families Organization systematically answers “NO” despite millions in transfers with entities sharing personnel, addresses, and operational control through Community Labor Administrative Services. (2023 Form 990, Schedule R)

This creates a clear pattern: meticulous compliance when disclosure serves coordination purposes (CLA relationship), systematic concealment when disclosure would reveal coordination (all other major relationships involving $10.19+ million in transfers).

Cross-Jurisdictional Contradictions:
The same leadership provides different information to different authorities:

  • To Federal Authorities (IRS): Deny coordination relationships on Schedule R
  • To Local Authorities (NYC Campaign Finance Board): Openly acknowledge shared personnel and addresses

This selective compliance proves the syndicate operates with sophisticated knowledge and strategic intent. They understand federal disclosure rules perfectly—they simply choose which ones to follow based on what serves their coordination purposes.

The Sophisticated Actor Standard:
The Working Families Party’s November 2022 documentation of coordination expertise raises questions about whether systematic concealment patterns represent potential oversight or evidence of willful circumvention:

  • Documented knowledge: “WFP coordinated a significant grassroots IE table” and multi-state operations
  • Regulatory expertise: Understanding of coordination disclosure requirements and compliance frameworks
  • 2023 systematic concealment: Same organization then engages in $10.19+ million bidirectional flows while denying relationships

Legal Significance: When organizations demonstrate comprehensive regulatory knowledge then engage in systematic concealment patterns while processing coordinated funding, it raises questions about potential willful circumvention rather than inadvertent violations. The combination of sophisticated actor evidence with systematic disclosure omissions transforms this case from coordination concerns to potential circumvention by experienced operators who understand exactly what they’re doing.

Discovery 2: Leadership Timing That Reveals Strategic Positioning

Federal tax filings reveal suspicious timing in leadership transitions that coincided with enhanced coordination patterns, providing new evidence of strategic positioning within the syndicate.

Dan Cantor’s Role Expansion:

  • 2021-2022: Director at Working Families Organization (501(c)(4)), 1 hour per week, $0 compensation (2021 and 2022 Form 990, Part VII, Section A)
  • 2023: Director at Working Families Organization (501(c)(4)), 40 hours per week (4,000% increase), still $0 compensation (2023 Form 990, Part VII, Section A)

This dramatic expansion occurred precisely when circular coordination patterns intensified, demonstrating strategic positioning within the syndicate rather than coincidental timing.

Mike Boland’s Dual Treasurer Problem: The same person serves as treasurer for entities claiming independence while providing contradictory information to different regulators:

  • Federal Filings: Treasurer of Working Families Organization (501(c)(4)), works 16 hours per week without compensation while the organization denies related organization relationships (2021, 2022, and 2023 Form 990, Part VII, Section A)
  • Local Filings: Treasurer of WFP National PAC-NYS IE Committee (Super PAC) while employed as Chief of Staff of Working Families Party, manages same-day circular transactions (NYC Campaign Finance Board, 2021 and 2025 disclosures)

Under election law, Independent Expenditure Committees cannot coordinate with candidates or their agents. Yet Boland works unpaid at Working Families Organization (501(c)(4)) while simultaneously serving as treasurer of the “independent” committee and being employed by Working Families Party, facilitating the 2025 same-day circular transactions totaling $54,290.69.

The Triple Role Coordination: Boland’s arrangement creates direct coordination across three supposedly independent entities – working unpaid at the 501(c)(4), employed by the Party, and serving as treasurer of the Super PAC. This triple role eliminates any pretense of independence between entities claiming no relationships on federal forms.

The ACORN Experience Factor:

Both Cantor and Working Families Party founding co-chair Bertha Lewis served in ACORN leadership before constructing this network. When ACORN collapsed amid regulatory challenges, its experienced leadership built new structures using sophisticated understanding of regulatory frameworks gained through decades of experience.

Discovery 3: The Shared Infrastructure Web — Community Labor Administrative Services Reveals All

The most significant operational discovery explains how entities processing $655.9 million in combined revenue report zero employees while maintaining coordination, proving the syndicate operates through shared infrastructure disguised as legal separation.

Enhanced Professional Employer Organization Network:
Community Labor Administrative Services serves as shared operational backbone across multiple entities claiming independence:

  • Working Families Organization (501(c)(4)): $863,783 for “PEO Services for Organizing Staff” (2018-2023)
  • Tides Advocacy (501(c)(4)): $347,866 for “Government Relations” (2023)
  • Center for Popular Democracy (501(c)(3)): Program consulting services through BaseBuilder LLC (2023)
  • New Jersey Working Families Alliance (501(c)(4)) (2014-2023)
  • United For Respect Education Fund (501(c)(3)) (2019-2021)

The “Zero Employees” Systematic Pattern:
Organizations processing massive revenue streams claim zero employees while sharing personnel:

  • Working Families Organization (501(c)(4)): $48.8 million revenue, zero employees
  • Tides Foundation (501(c)(3)): $350.1 million revenue, zero employees
  • Open Society Action Fund (501(c)(4)): $257 million revenue, zero employees
  • Center for Popular Democracy Action Fund (501(c)(4)): Uses “common paymaster” arrangements

Combined Zero Employee Revenue: $655.9 million managed by organizations reporting no direct employees

Physical Infrastructure Overlap:

  • 77 Sands Street, Brooklyn: Working Families Organization (501(c)(4)), WFP National PAC (527), Community Labor Administrative Services
  • 449 Troutman Street, Brooklyn: Center for Popular Democracy (501(c)(3)) (Suite A), Make the Road Action (501(c)(4)) (Suite C)

Campaign Finance Validation: NYS expenditure records spanning 2019-2025 confirm systematic shared infrastructure operations, with all network entities consistently operating from 77 Sands Street while engaging in cross-entity payments for wages, office expenses, and operational costs. This provides independent validation of the shared infrastructure claims through official financial disclosures across multiple years.

When organizations share payroll systems, facilities, operational staff, and engage in systematic financial coordination while claiming independence, legal separation becomes operational fiction designed to circumvent oversight. The enhanced CLA evidence proves the syndicate operates as a unified system disguised through legal structures, with the same entity providing critical services across the network while entities deny relationships on federal forms.

Discovery 4: December 2024 Validation and 2025 Mathematical Precision

The December 2024 Game Changer:
FEC records revealed a $2 million transfer from Working Families Organization to Working Families Party PAC in December 2024, fundamentally transforming the investigation’s scope and legal implications. This redistribution validates that coordination patterns documented in 2023 federal tax filings represent continuing systematic operations rather than historical compliance issues.

Legal Significance of Timing:
The December 2024 redistribution occurred months after our initial investigation was published, proving the syndicate continues operations with enhanced sophistication rather than compliance improvements. This timing preserves criminal prosecution options for continuing violations while enabling comprehensive enforcement action spanning multiple years.

Validation Framework:
The December 2024 redistribution validates that the $10.19 million convergence documented in 2023 federal filings contributed to systematic political coordination rather than independent charitable activities:

  • Channel 1: $5.15 million direct political convergence
  • Channel 2a: $4.56 million charitable-to-political conversion
  • Channel 2b: $430,173 indirect charitable conversion
  • December 2024 Validation: $2 million redistribution proving political coordination

2025 Mathematical Precision Evidence:
The four same-day circular transactions totaling $54,290.69 documented above provide definitive proof that the coordination continues with mathematical precision that eliminates any remaining doubt about systematic intent. Independent organizations never engage in penny-perfect same-day circular transactions while claiming independence.

Continuing Violations Framework:
The December 2024 validation and 2025 mathematical precision demonstrate this represents an active, continuing violation rather than historical compliance issues, creating enhanced enforcement options including:

  • Criminal prosecution options for continuing violations
  • Enhanced penalties for sophisticated circumvention by experienced operators
  • Comprehensive recovery across multiple years of systematic operations
  • Protection of ongoing investigation from statute of limitations concerns

Conclusion

The combination of strategic disclosure patterns, leadership timing, shared infrastructure, mathematical circular flows, and the December 2024 validation proves the existence of a sophisticated charitable-to-political syndicate. When organizations process $655.9 million in revenue through shared operational systems while claiming zero employees, engage in $10.19 million in systematic coordination while denying relationships, demonstrate mathematical precision through $54,290.69 in same-day circular transactions, and validate operations with a $2 million redistribution in December 2024, the evidence demonstrates systematic circumvention disguised as charitable work.

As documented in our September investigation, these coordination patterns represent ongoing systematic operations rather than isolated incidents. While the syndicate processes $655.9 million in combined revenue, the $10.19 million in documented coordination flows represents mathematical impossibilities that independent organizations would never engage in. The four new discoveries—strategic disclosure sophistication, suspicious leadership timing, shared infrastructure operations, and December 2024 validation with 2025 mathematical precision—eliminate any remaining doubt about whether this represents independent charitable work or a coordinated syndicate designed to circumvent oversight while processing taxpayer resources.

The mathematical evidence, spanning from 2023 federal tax filings through December 2024 FEC records to 2025 campaign finance documentation, demands accountability for this charitable-to-political syndicate operating at unprecedented scale and sophistication.

Analysis based on 2021-2023 IRS Forms 990/990-PF, December 2024 FEC filings, NYC Campaign Finance Board filings (2021-2025), NYS Board of Elections records (2019-2025), and independent audit reports. All evidence obtained through public records.

Follow @SamAntar on X for updates on this investigation

Written by Sam Antar | Forensic Accountant & Fraud Investigator

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