Did the Singham Network Move $100 Million Abroad Through a Charity With No Employees?

Neville Roy Singham’s network of American tax-exempt organizations is being examined, by Congress and by federal agencies, as a foreign-influence question: whether it functions as a vehicle for Chinese state messaging. That inquiry is real, it is contested, and others are pursuing it. This article is about something different, and narrower, and — for the people whose job is enforcement — more immediately actionable: a tax-compliance question that can be answered without resolving any of the influence debate at all.

The question is this. Whatever an organization’s mission or politics, a §501(c)(3) private foundation and the §501(c)(4) organizations it funds must follow the same Internal Revenue Code as every other charity in the country. That compliance is not a matter of opinion or motive. It is testable, line by line, on the returns these organizations filed with the IRS under penalty of perjury. And on those returns, one funding chain in the Singham network raises questions that the documents themselves do not answer.

This is the first in a series approached strictly from that tax angle. The foreign-influence story has its venue: the House Ways and Means Committee has called on the IRS to examine the network, and federal agencies are reportedly looking at related conduct. The tax-compliance question runs on a separate track. It does not require anyone to agree about China, about politics, or about Singham. It requires only reading the filings — and it carries its own enforcement consequences under the Internal Revenue Code, independent of every other inquiry. Singham himself is not the subject here. The subject is the money, and what the participants’ own tax returns do and do not show about it.

It begins where the public record is clearest: a single funding chain, and a single narrow question. When a private foundation routed tens of millions of dollars to organizations it itself called noncharitable, did anyone account for where the money went — as federal law requires — and if so, where is the trace of it?

The chain has three points. At the apex sits People’s Support Foundation Limited, a §501(c)(3) private foundation. Across fiscal years 2019 through 2024 it transferred $73,731,279 to two §501(c)(4) social welfare organizations in the Singham network — People’s Welfare Association and United Community Fund. People’s Welfare Association, in turn, reported moving $101,983,568 in grants abroad over the same period while reporting zero employees, zero officer pay, and nothing in the professional-fee categories — beyond routine legal and accounting — where the cost of administering or monitoring that money would most naturally appear. (Those are two different flows at two different points in the chain: the $73.7 million the foundation put in is separate from, and smaller than, the $101 million People’s Welfare Association sent out.)

That gap is the heart of this report. When a private foundation gives to an organization that is not itself a public charity, federal tax law stops treating the gift as routine. Internal Revenue Code §4945 requires the foundation to exercise “expenditure responsibility” — a defined set of monitoring, documentation, and reporting steps — or the grant becomes a “taxable expenditure” subject to excise tax.

Because People’s Welfare Association and United Community Fund are §501(c)(4) organizations rather than public charities, grants to them fall within that regime — and the foundation’s own filings put the point beyond dispute: on its Form 990-PF, in three separate IRS-designated places on the same return, it classified both recipients as noncharitable, foreclosing any suggestion that it believed it was funding public charities. Yet across six years of public filings, the paid-capacity footprint one would ordinarily expect for monitoring foundation-funded grants routed through a conduit that reported moving more than $100 million abroad is nowhere visible.

This article documents that conduct in the organizations’ own federal filings, available to anyone through the IRS and ProPublica. The findings have been referred to the Internal Revenue Service. It raises the questions those documents pose. It does not assert their answers — whether any tax is owed is for the IRS to determine.

The Entities in This Report

The organizations examined here share overlapping “People’s” names and a common funding structure, which can make them easy to confuse. They fall into two tax categories, and that distinction is the center of this report. The following table identifies each entity, its tax status, and its role.

People’s Support Foundation Limited is a §501(c)(3) private foundation; it files Form 990-PF. People’s Welfare Association and United Community Fund are both §501(c)(4) social welfare organizations; they file Form 990.

This is worth stating precisely, because it is the fact that makes everything that follows inescapable: both recipients have been §501(c)(4) organizations — not §501(c)(3) public charities — from their very first filed returns. There was no conversion, no earlier period as a public charity, no moment when a grant to them would have been routine. People’s Welfare Association selected the §501(c)(4) box on its first return for the fiscal year ending April 30, 2020, and the IRS determination recognizing it as exempt under §501(c)(4) was effective April 20, 2020.

From the first dollar to the last, every transfer the foundation made to these recipients was a transfer to a noncharitable organization — which means the §4945 expenditure-responsibility duty attached to every one of them, for the entire period, with no ambiguity about timing. The line between the §501(c)(3) foundation and the §501(c)(4) recipients is the line federal tax law draws between grants that require expenditure-responsibility monitoring and grants that do not — and it is the line this report examines.

Why This Matters

A grant from a private foundation to a public charity is generally unremarkable. A grant from a private foundation to a §501(c)(4) social welfare organization is different: under §4945(d)(4), it generally may be treated as a taxable expenditure unless the foundation exercises expenditure responsibility under §4945(h) — written grant agreements, monitoring of how the funds are used, and grantee reports back to the foundation, consistent with the statute and regulations. The rule exists precisely because §501(c)(4) organizations can do things — including political activity — that §501(c)(3) charities cannot, and Congress did not want private foundations functioning as untracked conduits into that space.

The legal stakes turn on that line, and they are concrete here. People’s Support Foundation Limited moved $73.7 million across it. The recipient that took the larger share, People’s Welfare Association, then moved more than $100 million abroad — to recipients whose identities are not on the public record — while reporting no employees and no professional-fee footprint of the kind monitoring at that scale would ordinarily require.

Expenditure responsibility is the mechanism federal law uses to make sure foundation money sent to a §501(c)(4) is restricted, tracked, and not diverted to purposes a foundation may not fund. Whether that mechanism was used is the question this record raises. Everything that follows is drawn from Forms 990 and 990-PF filed with the IRS and available to anyone through IRS.gov and ProPublica’s Nonprofit Explorer; each figure is tied to a specific form, schedule, and line.

Question One: The Foundation Called Its Own Recipients “Noncharitable” — in Three Places on the Same Return

On its 2024 Form 990-PF, People’s Support Foundation Limited classified People’s Welfare Association and United Community Fund as noncharitable recipients in three separate IRS-designated locations on the same return:

• Part XIV, “Foundation status of recipient” column. Every grant entry to People’s Welfare Association is coded “NC.” Every grant entry to United Community Fund is coded “NC.”
• Part XVI, Line 1a(1). The foundation answered “Yes” to whether it made “Transfers from the reporting foundation to a noncharitable exempt organization of: (1) Cash.”
• Part XVI schedule, column captioned “Name of noncharitable exempt organization.” Under that exact caption, the foundation lists “PEOPLES WELFARE ASSOCIATION” at $10,471,629 and “UNITED COMMUNITY FUND” at $425,000 for tax year 2024.

This is not an inference drawn from outside the return. It is the foundation’s own characterization, in the foundation’s own filing, in the boxes the IRS provides for exactly that purpose. That coding is evidence of how the filer viewed the recipient’s status for reporting; it does not itself create or substitute for the statutory requirements of §4945, which turn on the recipient’s actual status under the Code.

The same return shows the foundation knew how to code a recipient differently when it meant to. On that same 2024 Part XIV, People’s Support Foundation Limited coded its grants to The Justice and Education Fund Inc ($5,370,000 across two entries) and its $5,000,000 grant to The People’s Forum Inc as “PC” — public charity. On the same page, in the same column, the foundation distinguished public-charity recipients from noncharitable ones. It placed People’s Welfare Association and United Community Fund in the noncharitable category itself.

The same three-location pattern appears on the 2023 Form 990-PF, where the schedule lists People’s Welfare Association at $13,938,430 and United Community Fund at $100,000, both coded “NC.” Across fiscal years 2019 through 2024, the cumulative transfers were $66,476,279 to People’s Welfare Association and $7,255,000 to United Community Fund — a combined $73,731,279, each year documented on the foundation’s Part XVI.

Under §4945(d)(4), a private foundation’s grant to a noncharitable recipient is a taxable expenditure unless the foundation exercised expenditure responsibility. The applicability of that rule turns on the recipient’s actual status — a §501(c)(4) social welfare organization is not a public charity — and the nature of the grant; the foundation’s “NC” coding is consistent with, and probative of, that status, but the statutory duty flows from §4945 itself, not from the coding. The remaining question is whether the required oversight happened.

Question Two: $101 Million Out the Door — and No One on Staff to Account for It

This is the heart of the matter, and it is the one finding in this article that has not, to my knowledge, been documented elsewhere.

Performing expenditure responsibility on a grant is real work. The foundation (or someone acting for it, or the grantee maintaining the records the foundation relies on) must obtain written grant agreements, monitor how the money is spent, and collect reports back. On more than $100 million in grants flowing onward as foreign grants, that work is substantial.

The law permits a foundation to rely on others to perform parts of it — but performing it is not free, and if it is outsourced or staffed it generally leaves some trace. Payment for management, grant administration, monitoring, consulting, or professional services often has a designated home on the Form 990: Part IX, the Statement of Functional Expenses — though some costs can appear in other reasonable categories or be absorbed by a related entity.

People’s Welfare Association — the recipient of $66.5 million of the foundation’s transfers, and the disburser of more than $100 million in onward foreign grants over the period — reports the following on Part IX, Line 11 (Fees for services, non-employees), across all six reviewed years:

Across six years, People’s Welfare Association paid roughly $115,000 in legal fees and $340,000 in accounting fees — about $455,000 in total professional services against cumulative grant throughput of $101,983,568. That is approximately 0.45%. The amounts are consistent in scale and character with ordinary corporate compliance for a grantmaking nonprofit: annual Form 990 preparation and routine legal review.

Viewed solely through the categories and amounts reported on the public returns, they do not obviously reflect third-party performance of expenditure-responsibility monitoring on $101 million in foreign grants to recipients whose identities, written grant agreements, and grantee reports do not appear on those returns — though that observation is necessarily limited by what Part IX shows and how costs may be categorized.

Four of the IRS-designated categories on Part IX could capture outsourced monitoring of the kind §4945(h) contemplates: management (11a), lobbying (11d), investment management (11f), and other professional services (11g). People’s Welfare Association reported $0 in every one of those four categories, in every one of the six years. The categories where the cost of overseeing this money would most naturally appear are empty. If that work was done and paid for, where on the return does it show?

The organization also reported zero employees, zero officer compensation, zero key-employee compensation, and zero highest-compensated-employee compensation across the same six years. No one drew a paycheck. So who performed the pre-grant vetting, drafted the grant agreements, and reviewed the grantee reports that §4945(h) calls for — and on what record?

The organization’s own balance sheet sharpens the question. Across the six years, People’s Welfare Association reported total contributions received of $102,705,079 and foreign grants out of $101,983,568 — a difference of about $721,000, or roughly seven-tenths of one percent. It ended fiscal year 2024 holding $324,050 in net assets, against more than $100 million that had passed through it, with no liabilities.

Money came in and money went out, in nearly equal measure, year after year, with almost nothing retained and no one on staff. That is the financial profile of a pass-through conduit, not of an operating social welfare organization that runs programs of its own — and it is precisely the conduit pattern §4945’s expenditure-responsibility rule exists to police, because it is the structure through which untracked foundation money most easily reaches places a foundation may not fund.

(Of the $102.7 million in, the foundation supplied $66.5 million; the balance came from other sources. The point is not that every dollar out was the foundation’s — it is that the foundation’s dollars entered, and moved through, a vehicle that retained nothing and monitored, on the face of its filings, with no one.)

There is a further pattern worth noting, because it speaks to what the fees most plausibly represent. The cost of genuinely monitoring grants — vetting recipients, papering agreements, collecting and reviewing reports — is driven by the number and complexity of the grants, not by the size of the organization’s top line. So if these fees were monitoring cost, they should rise and fall with the grantmaking burden. They do not. The professional fees track the money coming in — and therefore the size of the return to be prepared — not the grantmaking going out.

The years bear this out. People’s Welfare Association’s fees were highest in fiscal years 2022 and 2023 ($102,791 and $86,646), the years its Schedule F reported foreign grants only as regional lump sums, with no individual grants itemized. In fiscal year 2024, by contrast, the same Schedule F itemized 28 separate foreign grants — each with its own amount and wire transfer, the most grant-level activity of any year — yet professional fees that year were lower, at $76,910. The year with the heaviest grant-by-grant burden cost less in professional fees than years with none of it itemized. That is the signature of routine return preparation, whose cost scales with revenue, rather than of grant monitoring, whose cost would scale with the grants themselves.

One caution belongs here in fairness: the IRS revised Schedule F for the 2024 tax year, and the appearance of itemized grants in fiscal year 2024 may reflect that form change as much as any change in practice. The point does not depend on the itemization being new. It is simpler: across every year, the fees moved with the inflow, never with the outflow’s grant complexity — which is not what monitoring cost would do.

There is an obvious objection to all of this, and it deserves a direct answer. The expenditure-responsibility duty under §4945(h) belongs to the foundation, People’s Support Foundation Limited — not to the grantee. So the right place to look for the cost of monitoring is the foundation’s own return, not People’s Welfare Association’s. And the foundation, unlike the grantee, does report substantial professional fees: its Form 990-PF Part I, Line 16, shows between roughly $540,000 and $617,000 a year in “other professional fees,” with total professional fees of about $636,000 to $731,000 in the years reviewed. A skeptic could reasonably say: there is the money that paid for the oversight.

Except the foundation’s own schedules say what that money was for. The Form 990-PF requires the “other professional fees” line to be itemized in an attached schedule, and People’s Support Foundation Limited’s schedule identifies the spend, every year, as investment management — the cost of managing the foundation’s endowment, not of monitoring its grants:

The same answer appears on the foundation’s Part VII contractor schedule, which lists its highest-paid independent contractors for professional services. Year after year the top of that list is investment management — $481,864 in 2024, and $548,395 across two managers in 2023. The remaining contractors the foundation names are described as investment management, legal, accounting, or consulting — among them Pomegranate Global Ltd (consulting, $94,950 in 2024) and Shanghai Maku Cultural Communications Co Ltd (consulting, $142,154 in 2023).

The foundation’s own descriptions place these outside grant oversight: it characterizes the work as investment management, consulting, legal, or accounting. None of those is the same thing as expenditure responsibility, which under §4945(h) means vetting grantees, securing written grant agreements, and collecting and reviewing grantee reports — the work a foundation must do to track money it has placed with a noncharitable recipient. A consulting or investment-management contractor is not, on the face of these filings, retained to perform it.

So the named contractors do not close the gap; they confirm it. Nothing on the foundation’s returns, in any year, is identified with the monitoring function. If any of these payments did cover that work, the schedules do not say so — and that silence is itself a question an examiner can put directly to the foundation.

So the objection turns back on itself. The foundation did pay for professional services — but its own filings say those services managed its investments. At neither end of the chain — not the grantee, which reported $0 in every category monitoring would occupy, nor the foundation, whose professional fees its schedules attribute to investment management — does the public record show a fee identified with the work §4945(h) requires.

One limit is worth stating plainly, because it is the honest boundary of any analysis built on public filings. Whether expenditure responsibility was actually performed can be documented in records the public cannot pull — board minutes, written grant agreements, grantee reports, review memoranda, and professional-services workpapers. The public returns cannot show what is in those files, and nothing here assumes the work was not done.

But there is a distinction those private files do not erase. Documentation of the work lives in private records; the cost of the work lives on the public return — because the Form 990 and Form 990-PF require it to. If monitoring on this scale was performed by paid staff or outside professionals, that expense had a mandatory home: the compensation lines, or the professional-fee categories of Part IX and Part I, Line 16.

A binder of grant agreements produced later would show the work was done; it would not explain why the expense of doing it is absent from the lines where the IRS requires expense to be reported. People’s Welfare Association reported $0 in those categories while moving $101 million abroad with no employees; the foundation reported its own professional fees as investment management. The records that prove the work may be private — but the dollars that paid for it, if there were any, were supposed to be public, and they are not there.

What the public returns can show, then, is this: the paid-capacity footprint that overseeing money at this scale would leave — the footprint the forms are designed to capture — is not visible on any of them. If the work was done and paid for, both the documentation and the matching expense exist somewhere. One of those is subject to IRS examination, and the other was supposed to be on the return already. That is exactly the kind of question an examination is built to answer.

Question Three: What the Missing Oversight Was Supposed to Guard Against — $15 Million in Political Contributions Downstream

The first two questions establish that the oversight §4945 requires is not visible in the record. This one is about why that absence matters — what the monitoring regime exists to catch, and what was flowing through the same conduit while it was not visibly being watched.

The rule treats grants to §501(c)(4) organizations with particular care for a specific reason. A §501(c)(4) can engage in political activity that private foundation funds are not permitted to support — and if foundation funds were used for such purposes, they could constitute taxable expenditures under §4945. Expenditure responsibility is the mechanism meant to ensure that does not happen. So the relevant question is what the record shows flowing through People’s Welfare Association during the years the foundation’s oversight is not in evidence.

The answer is on the organization’s own return. People’s Welfare Association’s Form 990 Schedule C, Part I-C, Line 2, discloses political contributions to §527 organizations totaling $15,017,020 across fiscal years 2019 through 2024. The same entity that received $66.5 million from a private foundation, and that maintained no visible monitoring capacity, reported making more than $15 million in §527 political contributions over the same period. This is precisely the category of use the foundation’s oversight obligation is meant to police.

Money is fungible, and the public record does not trace a particular grant dollar to a particular §527 contribution — which is precisely why §4945’s oversight regime exists. A foundation exercising expenditure responsibility is expected to restrict its funds, track their use, and confirm they were not spent on political contributions or election-related activity. So the question is direct: did those restrictions exist, and were they honored? The records that would answer it are the grant agreements and grantee reports §4945(h) calls for.

People’s Welfare Association also disclosed, across the period, that some of its grantees conduct activities that could be characterized as direct or indirect campaign activity — and, on its FY2024 Schedule F, described a grant purpose verbatim as “SOCIAL WELFARE SUPPORT TO GRANTEES THAT MAY ENGAGE IN POLITICAL ACTIVITY.” That is the organization’s own language on its own return.

Question Four: Where Are the Foreign Grantees?

People’s Welfare Association reported $101,983,568 in cumulative foreign grants across the six years, broken out by world region on Schedule F. The specific recipient organizations are not named on the public copies of those returns.

One clarification belongs here, in fairness, because it is the kind of thing easily mistaken for concealment. The blank recipient-name fields on Schedule F, Part II, columns (a) and (b) are not a disclosure violation. The IRS Instructions for Schedule F (Form 990) expressly direct filers not to complete those columns on the public copy. The absence of grantee names from the public Schedule F is what the IRS instructions require — not evidence that anything was hidden. The unnamed recipients are a feature of the public form, and this analysis treats them as such.

The point is therefore narrower, and sharper for being precise: the recipient identities, the written grant agreements, and the grantee reports that expenditure responsibility requires are not ascertainable from the public record — but they are fully ascertainable to the IRS through examination. The public filings establish that more than $100 million flowed abroad; they do not, by design, establish to whom. That is exactly why the monitoring records, if they exist, are what would demonstrate compliance with §4945(h) where it applies — and exactly why their absence from the public footprint is a question rather than an answer.

What the Documents Establish

• People’s Support Foundation Limited, a §501(c)(3) private foundation, transferred a combined $73,731,279 to People’s Welfare Association ($66,476,279) and United Community Fund ($7,255,000) across FY2019–FY2024, each transfer documented on its own Form 990-PF Part XVI.
• On the same returns, the foundation classified both recipients as “noncharitable” in three separate IRS-designated locations, while coding other recipients on the same page as public charities.
• People’s Welfare Association reported zero employees and zero compensation across all six years, and $0 in the four Part IX professional-fee categories (management, lobbying, investment management, other professional services) that could capture outsourced monitoring — while disbursing more than $101 million in foreign grants.
• Across the six years People’s Welfare Association received $102,705,079 in contributions and sent $101,983,568 abroad — retaining roughly $721,000, and ending FY2024 with $324,050 in net assets and no liabilities: the financial profile of a pass-through conduit rather than an operating organization.
• The foundation’s own Form 990-PF Part VII Line 3 and Part I Line 16 across 2019–2024 identify no contractor described as engaged to perform expenditure-responsibility services.
• People’s Welfare Association’s Schedule C discloses $15,017,020 in §527 political contributions across the same six years.

What the Documents Do Not Establish

• Whether People’s Support Foundation Limited in fact exercised expenditure responsibility under §4945(h) for the grants at issue. That defense can rest on nonpublic records — grant agreements, grantee reports, monitoring memoranda — that are not part of the public filings and that only an examination can review.
• Whether any specific foundation dollar was used for political activity in a way that would constitute a taxable expenditure under §4945. The §527 contributions are downstream of the foundation’s money, but the public record does not trace a particular grant to a particular contribution.
• What tax, if any, is owed. That is a determination for the Internal Revenue Service, not for me.

The Pattern, in One Place

Each of the facts in this report has, on its own, an innocent explanation. A foundation may fund §501(c)(4) organizations. An organization may have no employees and outsource its work. A charity may keep little in reserve. A foundation may pay its professionals to manage investments. A filer may leave Schedule F recipient columns blank, because the IRS instructs it to. Any one of these, standing alone, is unremarkable.

What the documents show is not one of these facts. It is all of them, in a single funding chain, at the same time:

• A private foundation classified its recipients as noncharitable three times on one return — while correctly coding other recipients as public charities on the same page.
• It moved $73.7 million to those noncharitable recipients over six years.
• The principal recipient had zero employees and zero compensation in every one of those years.
• That recipient received $102.7 million and sent $101.98 million abroad, retaining roughly $721,000 — a pass-through, not a program.
• It reported $0 in every professional-fee category where the cost of monitoring would appear.
• The foundation’s own professional fees, at the other end of the chain, went to investment management — not grant oversight.
• The foreign recipients of the $101.98 million are not named on the public returns.
• $15 million in political contributions sits downstream of the foundation’s money — the very use the monitoring rule exists to police.

An innocent account of this chain is possible. But it must explain not one of these features, but every one of them, together — each pointing in the same direction, in the same place, across the same six years. That is a great deal of coincidence to ask a single funding structure to carry. I am not asserting it was designed this way; intent is not something a tax return discloses, and I do not claim to read it. I am observing that the documents, read together, describe a structure in which more than $100 million moved through a no-employee conduit to unnamed recipients with no visible oversight — and asking the question a pattern like that is built to provoke: is there an innocent explanation for all of it at once, and where in the records would it be found? That is not a question I can answer from public filings. It is a question an examination is built to answer.

The pivotal fact is not that a private foundation funded §501(c)(4) organizations. It is that the foundation told the IRS, in its own hand, three times on the same return, that those recipients were noncharitable — and then moved $73.7 million to them over six years.

The returns are still on file. The 2024 Form 990-PF still codes People’s Welfare Association and United Community Fund “noncharitable” in three separate places. People’s Welfare Association’s six years of Form 990 still report zero employees, zero officer pay, and $0 in every monitoring-fee category — against more than $100 million in foreign grants. The foundation’s own contractor schedules still name no one engaged to monitor those grants.

The records that would show whether the law’s oversight requirement was met are not on the public returns; they exist, if at all, in nonpublic files an examination can review. The question is not whether this network’s politics are agreeable or its foreign ties troubling — those are arguments for another venue. The question is whether a private foundation and the organizations it funded followed the same tax law that binds every charity in the country. That question is answerable. The documents that raise it are the filers’ own, and anyone can read them.

— S.E. Antar

Why This Is Examinable — and by Whom

The value of a tax-compliance question is that it does not depend on motive, ideology, or any contested account of what this network is for. It depends on records. And the records that would resolve it are not lost or hidden — they are exactly the documents an authority with subpoena power is entitled to obtain: the written grant agreements, the grantee reports, the monitoring memoranda, the foundation’s correspondence with its §501(c)(4) recipients.

The public filings establish that more than $73 million moved from a private foundation to recipients it called noncharitable, that more than $100 million then moved abroad through an entity with no employees, and that no fee on any return is identified with the oversight the law requires. What the public filings cannot show is whether that oversight nonetheless occurred. That is a question an examination exists to answer, and the public record points to precisely where to look.

This also sits beside, but apart from, the inquiries already underway. Congressional committees and federal agencies are examining the Singham network on foreign-influence and sanctions grounds. The tax-compliance questions here are independent of those: they would remain whether or not any influence allegation is ever proven, because the Internal Revenue Code applies to every exempt organization regardless of what it advocates. For an examiner, an oversight body, or an investigator already looking at this network for other reasons, the tax track is a separate and self-contained line of inquiry — one that turns entirely on documents the filers themselves are required to keep.

This is also one chain in a larger network. The same public filings raise further questions about other entities, their cross-border flows, and the relationships among them. I will continue to follow the documents where they lead, and report what they show.

Methodology and Disclosure

I am a forensic accountant, not a journalist. Every figure in this article is drawn from Forms 990 and 990-PF filed with the Internal Revenue Service and available to anyone through IRS.gov, ProPublica’s Nonprofit Explorer, and similar public sources. Each dollar figure is tied to a specific form, schedule, and line.

Where I describe something as a documented fact, it comes from the face of a filing. Where I draw an inference, I have said so explicitly, and where the public record cannot answer a question, I have said that too.

I have reserved every legal conclusion for the authorities whose job it is to draw them. Whether the grants discussed here are taxable expenditures, whether expenditure responsibility was exercised, and what tax if any is owed are questions for the IRS. Nothing in this article is a legal conclusion that any person or organization violated the law.

I am a registered Democrat. My investigations follow the documents, not the politics — and the discipline cuts in every direction: where the filings show something is required by IRS instructions rather than evidence of wrongdoing, I say so, as this analysis does regarding the blank recipient columns on Schedule F. I hold that standard for everyone, and I would apply it to anyone.

By Sam E. Antar | WhiteCollarFraud.com
Sam Antar is a former CFO of Crazy Eddie who committed securities fraud before cooperating with federal authorities. He has spent over 30 years training the FBI, SEC, and DOJ on fraud detection. He follows the documents, not the politics.

Disclosure: I am a former felon who committed securities fraud at Crazy Eddie before cooperating with federal authorities. This analysis is based exclusively on public records. Nothing in this report constitutes a legal conclusion. Where I characterize something as a documented fact, it is sourced to a primary filing. Where I draw an inference, I have said so explicitly. I am a registered Democrat. My investigations follow documents, not politics.