Inside Job

In Part Six of this series I documented one side of a bipartisan phenomenon. The Arabella network. The Tides Nexus. The secondary layer of fiscal-sponsor architecture — Community Change, NEO Philanthropy, Wellspring, Proteus — through which an estimated $3 to $3.3 billion per year is moved from anonymous or foreign sources through tax-exempt American nonprofits into domestic political operations. Part Six closed with a commitment. The same legal architecture, the same operational techniques, and the same statutory exposure exist on the right side of American politics. The piece you are reading now is the fulfillment of that commitment. This is the right-side ledger. This is the structural parallel.

I want to be precise at the outset about what this piece is and what it is not. It is not an attempt to draw a moral equivalence between the left-side and right-side architectures, because such an equivalence is not in the documentary record. There are genuine asymmetries. The Wyss foreign-national funding scale ($245-280 million from a single Swiss billionaire to the Sixteen Thirty Fund and New Venture Fund) has no equivalent on the right side. California Governor Gavin Newsom's $187 million redirection of state taxpayer money to the Tides Center has no parallel in any Republican-led state. The specific operational overlap I documented in Parts One through Five — between federal workers, USAID/NDI-trained organizers, Chenoweth-and-Stephan civil-resistance methodology, and a Congressional caucus launch endorsing executive removal — has its funder side rooted in the Arabella, Tides, and secondary-layer architecture, not in the right-side ledger.

What the right-side ledger does have is something genuinely comparable in scale, identical in mechanics, and exposed to the same statutory framework. The Marble Freedom Trust, controlled by Federalist Society co-chairman Leonard Leo, received the single largest known donation to a politically focused nonprofit in U.S. history — $1.6 billion — from one Chicago electronics manufacturer in August 2021. That single transaction, through one entity, one donor, one stroke of legal architecture, exceeded the combined 2024 revenues of the Arabella and Tides networks. It also avoided up to $400 million in capital-gains tax that would otherwise have flowed to the U.S. Treasury. DonorsTrust, founded in 1999 by Whitney Lynn Ball, has moved more than $1.5 billion in cumulative donor-advised contributions through a structure that functions as the right-side analog to the Tides Foundation. The Charles Koch network — operating now under the brand name Stand Together — raised $578 million and spent $548 million in the 2024 federal election cycle alone, with hundreds of millions of dollars passed laterally between several 501(c)(4) entities to maximize political flexibility while remaining technically compliant with social-welfare-organization rules. The Federalist Society, nominally an educational 501(c)(3), has functioned for four decades as the operational clearinghouse for Republican judicial nominations.

The piece you are reading walks all of it. The same depth as Part Six. The same primary sources. The same statutory framework. And the same final position: the accountability test in American politics is whether the statutes get enforced against anyone operating these structures — not whether they get enforced selectively against one coalition. That is what bipartisan accountability actually requires.

DonorsTrust — The Right-Side Tides

The structural parallel begins in 1999. In Part Six I walked the Tides Foundation, founded in San Francisco in 1976 by Drummond Pike and tobacco heiress Jane Lehman as the first major fiscal-sponsor and donor-advised-fund architecture for the political left. The right-side analog was founded twenty-three years later, in Alexandria, Virginia, by a woman named Whitney Lynn Ball. Ball had spent the 1990s building the Philanthropy Roundtable, a network of conservative and libertarian donors, and serving as development director for the Cato Institute. In 1999 she launched DonorsTrust together with Kim Dennis, with seed support from a small group of donors active in libertarian and conservative philanthropy. DonorsTrust was structured as a 501(c)(3) public charity. Its companion entity, Donors Capital Fund, was structured as a 509(a)(3) supporting organization with the same staff and leadership; the only difference was that Donors Capital Fund served clients with account balances of $1 million or more.

The legal mechanism is identical to the one Part Six documented at the Tides Foundation. DonorsTrust is a donor-advised fund. A donor contributes cash or appreciated stock to a separate account inside the larger DonorsTrust 501(c)(3). The donor recommends grant disbursements to specific 501(c)(3) recipient charities. DonorsTrust takes legal ownership of the assets, retains discretion over the grants, and collects an administrative fee — currently 0.75% on the first $1 million, declining to 0.40% on amounts above $25 million. The donor receives an immediate tax deduction at the moment of contribution. The recipient organizations receive grants that, on their own Form 990 filings, are reported as having come from "DonorsTrust" — not from the original donor. The donor's identity does not appear on any public record. The structure is, in legal effect, a perfect anonymity vehicle for tax-deductible contributions to ideologically aligned 501(c)(3) recipients.

The cumulative scale by 2016 was already over $1 billion. In June 2016, DonorsTrust announced that it had passed $1 billion in cumulative donor-advised contributions since founding. By 2015, The Guardian reported, the combined disbursements of DonorsTrust and Donors Capital Fund had reached approximately $740 million. The current ten-year cumulative figure, on the most recent IRS Form 990 filings through 2024, exceeds $1.5 billion. In 2024, DonorsTrust gave $21.3 million to the America First Legal Foundation, the legal-action organization founded by former Trump White House senior advisor Stephen Miller. In 2024, DonorsTrust gave $4.4 million to the America First Policy Institute, the policy-development organization that has functioned as the operational policy shop of the Trump-aligned conservative coalition since the end of the first Trump administration. These are not small grants. They are operational-scale grants to the institutional infrastructure of a specific political coalition.

What DonorsTrust does not do, and what distinguishes it from the Arabella-Tides architecture in one important respect, is operate fiscally-sponsored "pop-up projects" under fictitious names. DonorsTrust grants flow to existing 501(c)(3) recipients — Heritage Foundation, Federalist Society, Americans for Prosperity Foundation, Cato Institute, Project Veritas (in years prior to that organization's collapse), the Foundation for Government Accountability. The recipients exist independently of DonorsTrust. They file their own Form 990s. They are subject to their own §501(c)(3) restrictions. The donor anonymity is preserved in the contribution chain, but the operational outputs of the recipient organizations are not hidden behind fictitious names registered under state law. That is a meaningful structural difference. It means DonorsTrust does not have the same disclosure-evasion exposure that Sixteen Thirty Fund's pop-up projects have. It also means that DonorsTrust's recipients are accountable to the IRS in a way that fiscally-sponsored pop-up projects are not. Whether that accountability is meaningful in practice is a separate question, addressed below.

The Climate-Denial Investigation and the Heartland Institute

The single most extensively documented investigative work on DonorsTrust was conducted by The Guardian and Drexel University environmental sociologist Robert Brulle, published in February 2013 and updated through 2015. The investigation documented that, between 2002 and 2010, DonorsTrust and Donors Capital Fund had together routed approximately $120 million to more than 100 organizations actively engaged in opposing climate-change regulation or in disputing the scientific consensus on anthropogenic global warming. The recipient organizations included the Heartland Institute, the Competitive Enterprise Institute, the Heritage Foundation, the American Enterprise Institute, the Cato Institute, the Mercatus Center at George Mason University, the Committee for a Constructive Tomorrow, and the State Policy Network. Brulle's analysis identified DonorsTrust and Donors Capital Fund as, between them, the single largest funders of organizations opposing carbon-emission restrictions over the 2003-2010 period.

The Heartland Institute case is the most operationally specific. Heartland's IRS Form 990 filings during the relevant period showed an "Anonymous Donor" providing donations that, in some years, exceeded 60% of the Institute's total annual revenue. By comparing the year-over-year amounts of the "Anonymous Donor" contributions against DonorsTrust's annual grant disbursements to Heartland, Brulle's analysis demonstrated that the contribution amounts were nearly identical year over year. The conclusion was straightforward: DonorsTrust was almost certainly the conduit through which the "Anonymous Donor" — later confirmed in 2015 by ProPublica reporting to be Tripp Lite owner Barre Seid, who reappears in Section II of this piece — was routing funds to the Heartland Institute while preserving his anonymity from the public record.

The relevance of this for Part Six's bipartisan thesis is direct. The donor-advised-fund architecture, on both the left and the right side of American politics, has the same fundamental property: it allows a donor to maintain immediate tax deductibility while obscuring the connection between the donor's identity and the operational outputs of the recipient organization. That is the structural parallel. It applies in both directions. The only differences are the recipient organizations and the donors' political preferences.

Project Veritas and the 2016-2020 Operational Period

The DonorsTrust-Project Veritas relationship is the cleanest available example of the donor-advised-fund architecture being used to seed an operational political-advocacy organization. In 2015, DonorsTrust granted Project Veritas $1.5 million. In 2016, the grant was $1.7 million, which constituted approximately 37% of Project Veritas's $4.6 million total budget that year. This pattern — DonorsTrust providing the major fraction of an operational organization's annual funding from anonymous-donor contributions — recurred across multiple Project Veritas fiscal years through approximately 2020. DonorsTrust President Lawson Bader, when asked about the pattern in 2020, stated: "for the last eighteen months, we have been subject to hostile emails, critical floor statements from Senators and members of the House, in-depth media coverage, and threatened Congressional investigations" because of grants made to Project Veritas. Bader added that Project Veritas's operational goal of "embarrassing politicians or highlighting the hypocrisy among political parties and its platforms does not make friends, especially those in powerful positions."

The Project Veritas case illustrates a specific concern about donor-advised-fund architecture that applies in both political directions. When an operational advocacy organization receives 37% or more of its annual budget from a single donor-advised fund, and the donor-advised fund's contributions are themselves attributable to a small number of anonymous individual donors, the operational organization is, in practical effect, controlled by those anonymous donors — even though the legal structure presents the relationship as a series of tax-deductible contributions and discretionary grants. The donors are not legally controlling the organization in any sense the IRS rules recognize. They are functionally controlling it, because the organization cannot survive without their grants and the grants are conditioned, through the donor-advisory mechanism, on the donors' approval. This is the same fact pattern that critics of Arabella-Tides have identified as the operational reality of fiscal sponsorship at industrial scale. It applies in both directions for the same structural reason.

The Leo Network — The Centerpiece

The single most operationally complex right-side dark-money architecture is the network controlled by Leonard Anthony Leo, co-chairman of the Federalist Society and longtime architect of the Republican judicial-nomination apparatus. The Leo network is genuinely larger and more operationally interconnected than any single component of the Arabella architecture. It includes a $1.6 billion 501(c)(4), a 501(c)(3)/(c)(4) twinned funding-hub structure with deliberately registered fictitious names, a Schwab Charitable laundering route that obscures the connection between the largest funding source and the operational output, and a for-profit consulting firm that has received approximately $100 million in payments from nonprofit entities the same person directs. The DC Attorney General's office has been investigating the network for §4958 self-dealing since August 2023. The investigation continues as of this writing.

I will walk this network in the order a federal prosecutor would walk it, starting with the source of funds and working downstream to the operational outputs.

Marble Freedom Trust — The Source of the Money

The architecture begins with a man named Barre Seid. Seid was born in 1932 in Chicago, the son of Reuben and Anne Seid, Russian Jewish immigrants. He attended the University of Chicago under a special accelerated bachelor's degree program. After two years of U.S. Army service, he returned to Chicago and took a position as assistant to investor Graham Trippe, owner of Trippe Manufacturing — an electrical-products manufacturer founded in 1922 that had pivoted in the 1980s to surge protectors and uninterruptible power supplies for the personal-computer market. By the mid-1960s Seid had assumed the presidency of the company, which subsequently rebranded as Tripp Lite. Seid ran Tripp Lite for more than fifty years. By 2018, the company contributed approximately $136 million to Seid's reported personal income, and Seid himself had become, on tax records reviewed by ProPublica, one of the wealthiest individuals in American politics whom Forbes had never named to its lists. The 2018 income figure was approximately $157 million for the year. Cumulative reported charitable donations from 1996 through 2018: approximately $775 million.

Seid considered himself a libertarian "with a little tilt toward Cato Institute libertarianism," in the words of his longtime adviser Steven Baer. His operational philosophy of giving — which Seid himself called "attack philanthropy" — was structured around the principle that conservative donors should accept long-odds bets in exchange for the prospect of "epochal change." Seid was the major patron of the Heartland Institute through the period of its climate-change-skepticism work. He was a primary funder of the renaming of the George Mason University School of Law to the Antonin Scalia Law School in 2016, with a $20 million anonymous gift that conditioned its disbursement on the law school's adoption of specific curriculum and faculty-hiring requirements. He funded Hillsdale College, which has become a feeder institution for staffers in the Trump administration. He has been linked, via 2008-2010 reporting in Salon, to the Clarion Fund's distribution of 28 million DVDs about radical Islam in swing states during the 2008 presidential election. He attended no political events. He gave no public interviews. His name appeared on no Forbes wealthiest-Americans list. He was, until August 2022, almost entirely unknown to the American public.

Marble Freedom Trust did not exist publicly. The group's name appeared in no public business, tax, or securities database for more than two years after its 2020 creation. The first public confirmation of the Trust's existence came in August 2022, when The New York Times and ProPublica simultaneously published the story based on documents reviewed by The Lever and ProPublica. As of April 2021, the Trust had over $1.4 billion in assets. As of the most recent IRS Form 990 filings, the Trust holds approximately $992 million in assets after several years of large grant disbursements. Leonard Leo, listed on the Trust's Form 990 as a member of the board of trustees, draws a salary of $350,000 per year for 25 hours of work per week. The Trust's secondary trustees are Tyler Green (administrative trustee, former law clerk to Justice Clarence Thomas, former Utah Solicitor General) and Jonathan Bunch, a longtime associate of Leo's. The Trust's stated mission, per its own filings: "to maintain and expand human freedom consistent with the values and ideals set forth in the Declaration of Independence and the Constitution of the United States."

That is the formal mission. The operational mission, per Leo's own statements, is more specific. In an interview with the Financial Times in September 2024, Leo stated that the Marble Freedom Trust would devote $1 billion to "crush liberal dominance" — particularly in news and entertainment — and to fight "companies and financial institutions that bend to the woke mind virus." That is a public, on-the-record commitment by the Trust's chairman to deploy approximately two-thirds of the Trust's total endowment toward a specific ideological campaign over the next decade. There is no equivalent public commitment by any single individual on the left side of the architecture documented in Part Six. The closest analog is the cumulative Soros giving through Open Society Foundations, but Soros's giving is distributed across hundreds of grantees and dozens of program areas. Leo's $1 billion commitment is concentrated.

The Concord Fund and the 85 Fund — The Twin Architecture

The next layer of the network is the structurally crucial one. In early 2020, two existing right-side nonprofits were operationally rebranded under the direction of Leonard Leo and his business partner Greg Mueller. The Judicial Crisis Network — a 501(c)(4) organization founded in 2005 to oppose George W. Bush's judicial nominees being blocked by Senate Democrats and to promote Republican judicial nominations — was renamed the Concord Fund. Its president, Carrie Severino (a former law clerk to Justice Clarence Thomas), retained operational control. The Judicial Education Project — a 501(c)(3) organization that Leo had co-founded in 2011 with longtime Republican fundraiser Neil Corkery — was renamed The 85 Fund. Severino became secretary of the 85 Fund as well. Both organizations relocated, on paper, to the same building as the Federalist Society — the same floor, the same hallway, in some cases adjacent suites.

The structural innovation of the rebrand was not the new names. It was what came next. In February 2020, both the Concord Fund and the 85 Fund filed with the Commonwealth of Virginia for permission to operate under fictitious names under state law. The Concord Fund registered its old name — Judicial Crisis Network — as a fictitious name. The 85 Fund registered its old name — Judicial Education Project — as a fictitious name. Both organizations also registered new fictitious names for new operational purposes. The 85 Fund registered "Honest Elections Project" (which began operating in April 2020 to file legal briefs against mail-in voting in the 2020 election). The Concord Fund registered "Honest Elections Project Action" as the (c)(4) twin. Both organizations subsequently registered "Free to Learn" and "Free to Learn Action" as a 501(c)(3)/(c)(4) twin to engage in the K-12 critical-race-theory political fight.

The reader who has read Part Six will recognize the architecture. It is the same fictitious-name pop-up structure that Sixteen Thirty Fund uses on the left side of American politics. The 501(c)(3)/(c)(4) twinning pattern, the registration of multiple fictitious names under a single legal entity, the operational deployment of the fictitious names for separate political-fight purposes — this is the same legal structure, used identically, on both sides of American politics. The state-law mechanism is the same. The federal tax-treatment difference (the 501(c)(3) takes tax-deductible contributions; the 501(c)(4) does not, but can spend more freely on political advocacy) is the same. The disclosure-evasion effect is the same. The accountability gap is the same.

The 85 Fund's revenues during this period reflected the scale. In 2020, the 85 Fund received $20 million from DonorsTrust. The 85 Fund's 2021 fiscal-year tax filing showed total revenues of $65 million, including a single donation of $48.5 million from a single anonymous donor. In 2022, the 85 Fund's revenues grew to approximately $134 million, of which approximately 95% — over $128 million — came from the Schwab Charitable Fund, a donor-advised-fund sponsor. The Schwab Charitable Fund's pass-through grants to the 85 Fund were $141.5 million in 2022 and $141 million in 2023.

The Schwab Charitable Laundering Route

Here is the structural innovation that has no parallel in the Arabella architecture. The Marble Freedom Trust does not pay the 85 Fund directly. Instead, Marble Freedom Trust grants large sums to the Schwab Charitable Fund — a donor-advised-fund sponsor that takes administrative legal ownership of the donations and then makes pass-through grants to the 85 Fund (and presumably to other recipients) under Marble's donor-advisory recommendation. Marble's own Form 990 for the 2022 tax year shows two separate grants to the Schwab Charitable Fund of $153.8 million and $153.75 million. The 85 Fund's Form 990 for the same period shows a $141.5 million grant from Schwab Charitable. The chain of inference, drawn by Lisa Graves of Court Accountability, by Bloomberg's Emily Birnbaum in May 2024 reporting, and by analysts at Inequality.org: the Schwab Charitable grant to the 85 Fund is the operational pass-through of the Marble Freedom Trust grant to Schwab Charitable, advised by Marble (or by Leo or by another person at Marble).

The reason this matters operationally is twofold. First, the donor-advised-fund pass-through obscures the source-to-recipient connection. The 85 Fund's Form 990 reports the Schwab Charitable Fund as the grant source. A reader of the 85 Fund's Form 990 cannot tell, from that document alone, that the funds originated at Marble Freedom Trust. Second, and more legally significant, the pass-through preserves the 85 Fund's status as a public charity under IRS rules. A 501(c)(3) organization that derives more than one-third of its revenue from a single donor over a four-year averaging period is, under §509(a)(2), at risk of being reclassified as a private foundation — a more restrictive status with stricter rules, more aggressive IRS supervision, and much heavier excise-tax exposure. By splitting the Marble funding through Schwab Charitable, the 85 Fund's "public support test" calculation treats each Schwab grant as coming from a distinct donor. The 85 Fund retains its public-charity status. The structural innovation is the laundering of the public-charity test, not the laundering of the dollars.

This is the kind of operationally specific maneuver that the IRS rules were not designed to prevent and that the §501(c)(3) public-support-test framework cannot, in its current form, reach. It is also the kind of maneuver that, under a properly resourced IRS Exempt Organizations Division and a properly seated Federal Election Commission, would be the subject of formal regulatory action. As Part Six documented, the FEC is currently in its second quorum collapse in seven years, with only two of six commissioners seated as of April 2026. The IRS Exempt Organizations Division has been operating with substantially reduced enforcement capacity since the 2013 Lerner-era political controversy and the subsequent budget cuts. Federal regulatory enforcement capacity, on both sides of the political ledger, is structurally disabled in ways that benefit precisely this kind of architecture.

The CRC Advisors / BH Group Self-Dealing Allegation

The most operationally significant aspect of the Leo network for purposes of this series is the §4958 self-dealing exposure. CRC Advisors — the for-profit successor to Creative Response Concepts, the firm Leo joined in 2020 after departing the Federalist Society's day-to-day leadership — is a Republican-aligned communications and consulting firm. BH Group is a separate for-profit limited liability company that Leo has identified, in past public disclosures, as his employer. According to Lisa Graves's analysis at Court Accountability, since the beginning of 2020, Leo's for-profit consulting firm CRC Advisors has received more than $100 million from nonprofit groups Leo helps direct. Of that, approximately $55 million has come from the 85 Fund — the same 501(c)(3) whose grants Leo's allies operationally control. The 85 Fund's most recent tax filings show payments of approximately $12 million per year to CRC Advisors for "consulting/advertising services."

This is the §4958 fact pattern. IRC §4958, the "intermediate sanctions" provision of the tax code applicable to tax-exempt organizations, prohibits "excess benefit transactions" between a tax-exempt organization and a "disqualified person" — defined as a person in a position to exercise substantial influence over the organization's affairs. Excess benefit transactions are subject to a 25% excise tax on the disqualified person, plus an additional 200% excise tax if the transaction is not corrected within a defined period, plus disqualification of the tax-exempt organization's status if the pattern is repeated. The complaint filed with the IRS and with the DC Attorney General's office in 2023 by the Campaign for Accountability — a watchdog group whose own funding history includes Arabella-network involvement, a fact the DC Attorney General has acknowledged — alleges that the $73 million payments from Leo-affiliated nonprofits to Leo's for-profit firms between 2016 and 2021 constitute excess benefit transactions under §4958.

Whether the allegation is correct on the merits is a question for the DC Attorney General's investigation and any subsequent litigation. What is not in dispute is that the operational pattern — large nonprofit-to-for-profit payments where the same individual exercises influence over both sides of the transaction — is the same fact pattern that, on the left side of American politics, the Wellspring Philanthropic Fund's $124.2 million in self-dealing transactions documented in Part Six presents. The §4958 statutory framework applies identically to both. The DC Attorney General's investigation is a real-time test of whether the framework will be enforced. As of this writing, the investigation continues. Republican congressional committees have launched their own counter-investigation of the DC Attorney General. The Concord Fund, one of the Leo-affiliated nonprofits under investigation, made a $250,000 contribution to a House Republican leadership PAC one day after the House Judiciary Committee threatened to subpoena DC Attorney General Brian Schwalb. The Concord Fund's previous contributions to federal PACs had been zero for nearly nine years. The timing is, at minimum, conspicuous.

The Koch Network — Stand Together

The Koch network is, in operational terms, the most institutionally mature dark-money architecture on the right side of American politics. It predates the Marble Freedom Trust by more than three decades. Its origins lie in 1984, when Charles and David Koch — sons of Fred Koch, the founder of Koch Industries — together created Citizens for a Sound Economy, a right-leaning grassroots-organizing operation that eventually split into Americans for Prosperity (AFP) and FreedomWorks. The Koch brothers, working through a constellation of donor networks and 501(c)(4) social-welfare organizations, built what is commonly described as the most sophisticated political infrastructure in American conservatism. After David Koch's death in 2019, Charles consolidated the network's branding under a unified name: Stand Together.

The 2024 election-cycle scale is documented in tax filings reviewed by The New York Times and published in December 2025. During the 2024 cycle, the Koch network raised approximately $578 million and spent approximately $548 million. The two flagship Koch political and policy organizations, the 501(c)(4) nonprofit Americans for Prosperity and its affiliated super PAC Americans for Prosperity Action, took in $397 million and $181 million from donors over that period. Charles Koch directed more than $5 billion in Koch Industries stock into the network between 2020 and 2022 — establishing the long-term funding base that has supported the network's operational deployments since.

The Stand Together C4 Fund — A Pass-Through With No Employees

The structural innovation in the most recent Koch network architecture is an entity called the Stand Together C4 Fund. The Stand Together C4 Fund is a 501(c)(4) organization that, per its own filings, has zero employees. It exists as a pass-through. During the 2024 cycle, Stand Together-affiliated entities funneled at least $630 million through the Stand Together C4 Fund. The Fund, in turn, directed approximately $350 million of that money to Americans for Prosperity (the 501(c)(4) operational organization) and to the Stand Together Chamber of Commerce (the 501(c)(6) trade-association-style entity that serves as the network's operational hub). The Stand Together Chamber of Commerce subsequently financed Americans for Prosperity and its super PAC with just under $330 million in cash and services. Koch Industries directly contributed an additional $40 million to AFP Action.

The reason for this structural complexity is the same reason that applies on the left side of American politics. A 501(c)(4) social-welfare organization may not spend more than 50% of its annual budget on direct political-campaign activity. A 501(c)(6) trade association is subject to similar but distinct rules. By passing money laterally between several entities — each of which, on its own, complies with its own organizational-purpose rules — the Koch network maximizes the political-flexibility of the aggregate spending while keeping each individual entity within its own statutory limits. This is, again, the same legal logic that produced the Arabella architecture's lateral money movements between Sixteen Thirty Fund, New Venture Fund, Hopewell Fund, and the Sixteen Thirty Foundation. The IRS rules permit the structure. The structure produces operational outcomes that the rules were arguably not designed to enable.

Americans for Prosperity — The Twenty-Year Operational Base

Americans for Prosperity, founded in 2004, is the longest-operating 501(c)(4) social-welfare organization in the conservative ecosystem. Through its affiliated hybrid super PAC AFP Action, AFP has spent more than $257 million in cumulative federal-election spending since 2004 to support conservative congressional and presidential candidates. In 2022, the most recent fiscal year for which complete tax data is available at the time of this writing, AFP's 501(c)(4) reported revenues of $112 million. AFP's foundation, the 501(c)(3) educational arm, has filed 23 amicus briefs to the U.S. Supreme Court in 2023 and 20 in 2024, including in cases on campaign-finance disclosure. AFP's stated argument in No On E v. Chiu, a 2024 case on California disclosure rules: requiring political advertisers to name their donors' donors would, in AFP's brief, "abridge their First Amendment rights to speak anonymously and associate freely."

The Walton family — Walmart founder Sam Walton's three surviving heirs Robert, Jim, and Alice Walton — have together donated at least $25 million to AFP Action in the 2024 cycle. AFP Action endorsed Nikki Haley in the 2024 Republican presidential primary and spent more than $40 million on her behalf, deepening a long-running ideological rift between the Koch network and Donald Trump. The Koch network's Trump-skeptical posture is not a recent development. After Trump's 2016 victory, the network retooled its political philanthropy. After Trump's 2024 victory, AFP committed $20 million toward extending Trump's first-term tax cuts — but the operational tension with the administration on tariffs and immigration has continued. The network's political flexibility is the structural point. It is a permanent ideological infrastructure that survives any specific administration.

The Comparison Across Networks

Unlike the Leo network, the Koch network does not appear to operate with the same fictitious-name pop-up architecture that Arabella, the 85 Fund, and the Concord Fund all use. The Koch network's entities — Americans for Prosperity, Americans for Prosperity Action, Stand Together C4 Fund, Stand Together Chamber of Commerce, Charles Koch Foundation, Charles Koch Institute — exist under their own permanent legal names. The lateral transfers between them are documented on each entity's annual Form 990 filings. The network's donor base is not anonymous in the way Marble Freedom Trust's is — Charles Koch is the network's primary funder, the funding pattern is publicly known, and the network has not denied that fact. In this respect, the Koch network is structurally more transparent than either the Marble Freedom Trust or the Sixteen Thirty Fund. Its donor identity is acknowledged. Its operational entity names are stable. Its money flows are traceable through public Form 990 filings.

The trade-off for this transparency is scale. The Koch network's combined 2024 spending of $548 million is substantial, but it is less than half of the Arabella network's $1.51 billion in 2024 revenues alone. The Marble Freedom Trust's $1.6 billion endowment is concentrated, but its annual spending in any given year is significantly lower than the cumulative spending of the Arabella sisters. The right-side architecture, viewed in aggregate, is operationally smaller than the left-side architecture documented in Part Six. That is not a partisan claim. It is what the Form 990 filings and the campaign-finance reports show, side by side, when read against each other.

The Federalist Society — The Judicial Pipeline

The right-side architecture has one institutional layer that the left-side architecture does not have a structural parallel for: the institutional infrastructure of judicial nominations. The Federalist Society for Law and Public Policy Studies, founded in 1982 at Yale Law School, the University of Chicago Law School, and Harvard Law School, has functioned for more than four decades as the operational clearinghouse for Republican judicial nominations. The Society's founding co-chairs were future Justices Antonin Scalia and Robert Bork, then-Yale law professor Steven Calabresi, and a small group of conservative legal scholars who believed the federal judiciary had drifted ideologically away from the original constitutional text. The Society's stated purpose is educational. It hosts conferences, panel discussions, debates, and student-chapter events at law schools throughout the country. Per the Society's most recent IRS Form 990 filings, it operates as a 501(c)(3) educational organization with 2024 assets of approximately $48 million and total expenses in the range of $25-30 million per year.

The president and CEO of the Society, since 1991, has been Eugene B. Meyer. Meyer's 2019 Form 990-reported compensation was $706,619. The Society's leadership board includes co-chairs Steven Calabresi and Leonard Leo, plus Lee Liberman Otis (founding director, former Associate White House Counsel under George H.W. Bush) and a roster of prominent conservative legal scholars and judges. The Society's 2024 annual gala, held shortly after Donald Trump's election to a second term, featured a conversation between Justice Neil Gorsuch and Justice Stephen Breyer.

"One-Third of the Justices"

The Federalist Society's operational role in Republican judicial nominations is the longest-running and most successful institutional pipeline in modern American conservative politics. Three Trump-nominated justices — Gorsuch, Kavanaugh, and Barrett — were drawn from a list of judicial-nomination candidates that Leonard Leo, then the Society's executive vice president, helped assemble and present to the Trump campaign in 2016. Justice Samuel Alito and Justice Clarence Thomas, both nominated by earlier Republican administrations, have long-running affiliations with the Society — Alito as a panelist at Society events going back to 2000, Thomas with affiliations dating to the 1980s. The Washington Post has written that "few people outside government have more influence over judicial appointments now than [Leonard] Leo." Legal analyst Jeffrey Toobin, in 2017, wrote that Leo was "responsible, to a considerable extent, for one third of the justices on the Supreme Court." During Trump's first administration, Trump described the Federalist Society and Leo's work on judicial nominations as "one of the greatest achievements" of his presidency.

This is a function the left-side architecture does not perform institutionally. The Democratic Party's judicial nominations during the Obama administration and the Biden administration were managed by the White House Counsel's Office and the Senate Judiciary Committee staff, with input from the American Constitution Society — a substantially smaller organization than the Federalist Society and not structurally analogous in any meaningful way. There is no left-side institutional equivalent to the Federalist Society's role as a permanent infrastructure for judicial-nominee vetting and promotion that survives across multiple Republican administrations. That is a structural asymmetry that runs in favor of the right-side architecture, not against it. It is also why the operational stakes of the §4958 self-dealing investigation against Leo are higher than the analogous stakes for any single individual on the left-side ledger. Leo's removal from the Federalist Society's executive vice presidency in 2020 did not end his operational role in the network. It transferred his role to a different vehicle — CRC Advisors — that was directly compensated by the nonprofits he continued to direct.

The Architects — Eight Biographies

The same biographical method I applied to the ten Arabella-Tides architects in Part Six applies here. The right-side architecture is built and operated by people. None of them, viewed in isolation, has done anything illegal. The pattern across the eight is what matters. Below are the profiles.

The Right-Side Money Flow

The diagram below presents the right-side architecture in the same four-tier form Part Six used for Arabella-Tides. Tier I is the ultimate funding source. Tier II is the primary vehicle. Tier III is the laundering or pass-through layer. Tier IV is the operational output.

The Right-Side Grantee Receipts — Twenty Examples

The same documentary method I applied to the Arabella-Tides grantee table in Part Six applies here. Below is a representative sample of grant transactions on the right-side ledger, drawn from publicly available IRS Form 990 filings and contemporaneous reporting. Each row is sourced. Each amount is verified. The sample is not exhaustive — many smaller grants from DonorsTrust, the 85 Fund, the Concord Fund, AFP, and other right-side funders are not represented. The intent is to demonstrate the operational scale and recipient diversity, not to provide a complete enumeration.

Year	Source	Recipient	Amount	Purpose & Notes
2020-2021	Barre Seid (Tripp Lite stock)	Marble Freedom Trust	$1.65B	Largest single donation to a political nonprofit in U.S. history · Tax structure avoided ~$400M in capital gains
2022	Marble Freedom Trust	Schwab Charitable Fund	$153.8M	First of two 2022 transfers · Pass-through to 85 Fund per donor advisory
2022	Marble Freedom Trust	Schwab Charitable Fund	$153.75M	Second 2022 transfer · Combined total to Schwab in 2022: $307.55M
2022	Schwab Charitable Fund	The 85 Fund	$141.5M	95% of 85 Fund's total revenue · Public-support-test laundering route
2023	Schwab Charitable Fund	The 85 Fund	$141M	Continued pattern from 2022 · Marble Freedom Trust source per documentary inference
2022	Marble Freedom Trust	Concord Fund	$55.5M	Direct grant · Concord Fund operates as Judicial Crisis Network and Honest Elections Project Action
2022-2023	Marble Freedom Trust	Total disbursed	$216.8M	Per Fox News reporting on 2022 fiscal year tax forms · Up $34.1M from previous year's $182.7M total
2020	DonorsTrust	The 85 Fund	$20M	Pre-Schwab pass-through era · Direct DonorsTrust to 85 Fund grant
2024	DonorsTrust	America First Legal Foundation	$21.3M	Stephen Miller's legal-action organization · Up from $3.2M in 2023
2024	DonorsTrust	America First Policy Institute	$4.4M	Trump-aligned policy-development organization · Up from $159,200 in 2023
2010	DonorsTrust	Americans for Prosperity Foundation	$7.7M	44% of AFP Foundation's total annual revenue that year
2016	DonorsTrust	Project Veritas	$1.7M	37% of Project Veritas's $4.6M annual budget that year
2002-2010	DonorsTrust + Donors Capital Fund	Climate-skeptic organizations (100+)	$120M	Per Guardian/Brulle investigation · Heartland, CEI, Heritage, AEI, Cato, Mercatus, etc.
2020-2021	The 85 Fund	CRC Advisors (Leo for-profit)	$55M+	Per Court Accountability/Lisa Graves analysis · §4958 self-dealing exposure
2024	Charles Koch Industries	Americans for Prosperity Action	$40M	Direct corporate contribution · Two payments May 2023 and July 2024
2024	Stand Together Chamber of Commerce	Americans for Prosperity Action	$43M	Pass-through · CCKC4 Charles Koch entity contributed $150M to Stand Together over 2021-22
2024	Walton family (Robert, Jim, Alice)	Americans for Prosperity Action	$25M+	Walmart founders' heirs · Direct super-PAC contributions
2024	Stand Together C4 Fund	AFP / Stand Together Chamber	$350M	Pass-through entity with zero employees · 2024 cycle aggregate
2023	Concord Fund	House GOP Leadership PAC	$250K	One day after House Judiciary Committee subpoena threat against DC AG · First federal PAC contribution by Concord in nearly 9 years
2014-2024	Concord Fund (and predecessor JCN)	Republican Attorneys General Association	$20M+	Cumulative contributions to RAGA · Operational coordination with state AGs

The reader will recognize the pattern from Part Six's grantee table. The transfer mechanics are essentially identical. The donor anonymity preservation, the lateral movement between affiliated entities, the use of donor-advised-fund pass-throughs to obscure source-recipient connections, the §4958 self-dealing exposure where the same individual exercises influence over both sides of the transaction. The right-side architecture and the left-side architecture are operationally parallel. They are funded by different donors. They produce different outputs. They serve different political coalitions. But the legal mechanism is the same.

Where the Architectures Differ — The Genuine Asymmetries

I want to be precise about this section. A bipartisan-accountability piece is not the same as a both-sides-are-the-same piece. The architectures are operationally parallel. That does not mean they are identical. There are six specific asymmetries between the left-side and right-side dark-money architectures that are documented in the public record. Some run in favor of the left side. Some run in favor of the right side. Honesty about which is which is the editorial cost of writing a serious bipartisan-accountability piece.

Asymmetry One — Foreign-National Funding Scale

The largest individual non-citizen donor on the right-side ledger has no equivalent to Hansjörg Wyss. Wyss, the Swiss billionaire and founder of Synthes, has donated an estimated $245-280 million to the Sixteen Thirty Fund and New Venture Fund since 2016. The Sixteen Thirty Fund's $130+ million in ballot-measure spending across 26 states since 2014 is, by primary funding source, Wyss-funded. There is no comparable single foreign-national donor on the right side of American politics. Barre Seid is American. Charles Koch is American. The Walton heirs are American. The Bradley Foundation, the Sarah Scaife Foundation, the John M. Olin Foundation, the Lynde and Harry Bradley Foundation — these are all American foundations whose donor pools are American citizens. The Wyss asymmetry runs distinctly in favor of the left-side architecture having a unique exposure to the 52 U.S.C. § 30121 ballot-measure-loophole question. The right-side ledger does not have an equivalent vulnerability.

Asymmetry Two — Public Taxpayer Money Pipeline

Part Six documented Governor Gavin Newsom's office and California state agencies directing approximately $187 million in California taxpayer funds to the Tides Center between January 2019 and April 2024. There is no Republican-led-state equivalent in the public record. No Texas, Florida, or Tennessee governor has been documented redirecting comparable amounts of state taxpayer money to a right-side fiscal-sponsor network. The closest analog the right-side architecture has is the Charles G. Koch Charitable Foundation's funding of George Mason University academic programs through agreements that condition the grants on specific curriculum and faculty-hiring requirements — which is a structural concern in a different category than the Newsom-Tides relationship. The Newsom-Tides asymmetry runs distinctly in favor of the left-side architecture having a unique exposure to the public-money-redirection question. The right-side ledger does not have an equivalent.

Asymmetry Three — Coalition-Operational Overlap with Federal-Worker Organizing

The specific operational pattern documented in Parts One through Five of this series — the FWAD strategy call, the Federal Workforce Caucus launch, the November 18, 2025 "illegal orders" video by six members of Congress, the intelligence-community committee-placement pipeline — has its funder side rooted in the Arabella, Tides, and secondary-layer architecture. The Democracy Forward 501(c)(3) sponsorship of FWAD, the State Infrastructure Fund's role in the affiliated coalitional organizations, the Wellspring Philanthropic Fund's grants to the litigation-coordination operations — these are documented in Part Six. The right-side architecture does not present a comparable documented operational overlap with sitting federal-employee organizing or active-duty military communications campaigns. The right-side architecture's operational outputs are concentrated in judicial nominations, election-procedure litigation, issue-advocacy advertising, state ballot-measure campaigns, and policy-think-tank research. None of these involves the same kind of internal-federal-worker organizational mobilization that Parts One through Five documented. This asymmetry runs in favor of the left-side architecture having a unique exposure to the kind of coalition-of-the-willing infrastructure pattern this series has named "color revolution."

Asymmetry Four — Donor Identity Concentration

This asymmetry runs in the opposite direction. The Marble Freedom Trust is a single-donor entity. One person — Barre Seid — funded the entire $1.6 billion endowment. Leonard Leo's operational network, while it has multiple ancillary donors at smaller scale, is fundamentally dependent on Marble Freedom Trust funds passed through Schwab Charitable. The Charles Koch network is a multi-donor coalition (approximately 200 Stand Together-network donors at $100K+ annual minimums), but Charles Koch is the central operational figure and his preferences drive the network's strategic choices. The right-side architecture is, in operational terms, more concentrated than the left-side architecture. The left-side architecture is more distributed. The Sixteen Thirty Fund, the Tides Foundation, and the New Venture Fund have hundreds of donors each. No single individual on the left side, with the partial exception of Wyss in the ballot-measure category, has the structural-control position that Leo or Charles Koch has on the right side.

This asymmetry has implications in both directions. It means the right-side architecture is more vulnerable to a §4958 self-dealing case targeting one or two key individuals. It also means the right-side architecture is more identifiable to the public — Charles Koch is a publicly named operational principal in a way that, for example, the various Sixteen Thirty Fund donors are not. The transparency of operational principals favors the right-side architecture. The concentration of operational principals exposes the right-side architecture to enforcement risk that the more-distributed left-side architecture does not face.

Asymmetry Five — Institutional Maturity and Judicial Pipeline

The Federalist Society's four-decade institutional infrastructure for judicial nominations has no left-side equivalent. The American Constitution Society, founded in 2001, is the closest analog. ACS is a smaller organization with substantially less institutional weight, less penetration into the Republican-administration nomination apparatus, and less continuity across multiple administrations. The right-side architecture's structural ability to place judges is, in operational terms, more institutionalized than any function the left-side architecture performs. This is a structural asymmetry that runs in favor of the right-side architecture being able to sustain ideological influence across multiple administrations even when its political coalition does not control the White House. It is also a structural asymmetry that creates §501(c)(3) exposure for the Federalist Society in a way that the left-side architecture does not face — because the Federalist Society's role in vetting and promoting specific judicial nominees is, in legal terms, harder to defend as "educational" activity under the §501(c)(3) framework than the analogous left-side think-tank advocacy.

Asymmetry Six — Federal Enforcement Symmetry

The final asymmetry is, paradoxically, a symmetry. Both sides of the architecture operate in a federal regulatory environment in which the FEC has been in quorum-loss for substantial portions of the last seven years, the IRS Exempt Organizations Division has been operating with reduced enforcement capacity since the post-2013 Lerner controversy, the CARES Act Oversight Commission was structurally disabled for its entire five-year statutory existence, and the Department of Justice's resources for §501(c)(3) and §4958 enforcement have been concentrated on a small number of high-profile cases on both sides of the political ledger. Neither side of the dark-money architecture is currently subject to robust federal regulatory enforcement. Both sides benefit from the structural disabling of the relevant agencies. This is the meta-pattern Part Six documented, and it applies symmetrically to both political coalitions.

The DC Attorney General's Investigation — A Real-Time Test

The most important active accountability process in the right-side architecture is the District of Columbia Attorney General's investigation of Leonard Leo and his network of nonprofits. The investigation began in approximately August 2023, when the Campaign for Accountability — a left-aligned watchdog group with prior Arabella-network involvement, a fact the DC Attorney General has acknowledged in public correspondence — filed a complaint with both the IRS and the DC Attorney General's office alleging that Leo's nonprofit network had violated §4958 by paying excessive consulting compensation to Leo's for-profit firms BH Group and CRC Advisors. The complaint specifically alleged that Leo had directed approximately $73 million in such payments from Leo-affiliated nonprofits to his for-profit firms between 2016 and 2021.

DC Attorney General Brian Schwalb, a Democrat elected in 2022, opened an investigation. The investigation's existence was first reported by Politico in August 2023. Schwalb's office has consistently declined to comment on the investigation's status, citing standard prosecutorial confidentiality.

The Counter-Pressure Campaign

What followed is one of the more remarkable institutional-pressure campaigns in recent American legal-accountability history. In October 2023, House Judiciary Committee Chairman Jim Jordan (R-OH) and House Oversight Committee Chairman James Comer (R-KY) launched their own investigation — of the DC Attorney General. The two chairmen sent a letter to Schwalb on October 30, 2023 demanding that he turn over all documents and communications related to his investigation of Leo. The letter framed Schwalb's investigation as "improper and politically motivated" and argued that Schwalb did not have jurisdiction over Leo because Leo and his organizations were primarily based outside Washington, D.C. Schwalb's response, sent November 13, 2023, declined to provide the requested materials, citing standard prosecutorial-confidentiality grounds.

In December 2023, Jordan and Comer threatened to subpoena Schwalb. One day after the threat, the Concord Fund — one of the Leo-affiliated nonprofits under investigation — made a $250,000 contribution to a House GOP leadership PAC. The Concord Fund had not made any federal PAC contributions in nearly nine years prior to that single payment. The timing is documented in FEC disclosures.

In September 2024, twelve Republican state attorneys general, led by Texas Attorney General Ken Paxton, sent a coordinated letter to Schwalb arguing that he lacked jurisdiction to investigate Leo. The Republican AGs' letter included an implicit warning: that conservative state attorneys general might face pressure to investigate progressive-oriented nonprofits if Schwalb did not back down from the Leo investigation. The Republican Attorneys General Association — which has, since 2014, received more than $20 million in cumulative contributions from the Concord Fund and its predecessor Judicial Crisis Network — was the operational vehicle through which the twelve-state letter was coordinated.

The Conservative Media Pressure

Concurrent with the institutional pressure, a parallel conservative media pressure campaign targeted Schwalb on issues unrelated to the Leo investigation. The pattern, documented in Politico's March 2024 reporting: a top Leo lieutenant (Carrie Severino, president of the Concord Fund) posted a tweet criticizing Schwalb's response to a question about juvenile-justice rehabilitation policy at a January 2024 panel discussion. The tweet was retweeted by numerous conservative-media accounts. The Washington Examiner ran a story citing the tweet on February 12, 2024. Fox News ran a story citing the tweet on February 1, 2024 with the headline "'Madness'." None of the stories addressed Schwalb's actual policy position; all of them characterized Schwalb's juvenile-justice-rehabilitation comment as evidence of broader prosecutorial unfitness. The pattern is a textbook example of coordinated media pressure operating as a defensive layer around an ongoing legal-accountability investigation. Whether the pattern is operationally connected to the Leo network's legal defense is a question that, again, the DC Attorney General's investigation will, in time, answer.

Why the Statutory Hooks Work in Both Directions

The statutory framework that Part Seven of this series will walk in detail applies symmetrically to the left-side and right-side architectures. The reason is that the statutes were not written for one political coalition. They were written for the operational pattern. When the operational pattern is the same, the statutes apply with equal force.

IRC §501(c)(3) — the public-charity tax-exemption framework — restricts political-campaign intervention by exempt organizations. The Federalist Society's role in Republican judicial nominations and the American Constitution Society's analogous role in Democratic judicial nominations are both subject to the same §501(c)(3) restrictions. The 85 Fund's litigation-coordination role through Honest Elections Project and the New Venture Fund's analogous role through its various sponsored projects are both subject to the same restrictions. The Tides Center's fiscal sponsorship of operational political-advocacy organizations and DonorsTrust's grants to operational political-advocacy organizations are both subject to the same restrictions. The statutory framework does not distinguish between left and right.

IRC §4958 — the intermediate-sanctions framework on excess-benefit transactions — applies identically to the Wellspring-Matan B'Seter $124.2M self-dealing pattern (documented in Part Six) and the Leo-CRC Advisors $100M self-dealing pattern (documented above). The statutory framework does not care whether the disqualified person is a libertarian Chicago industrialist or a Hong Kong-based anonymous-gift donor-advised-fund principal. The framework cares whether the operational pattern fits the statutory definition. In both cases, the operational pattern fits.

IRC §6033 — the annual reporting requirements for tax-exempt organizations — applies identically to the donor-advised-fund pass-through routes (Schwab Charitable for the right side, Vanguard Charitable for some left-side structures) and to the fiscal-sponsorship pop-up project structures (Sixteen Thirty Fund's "Protect the Investigation" on the left, Concord Fund's "Honest Elections Project Action" on the right). The statutory framework was, in retrospect, not designed to reach these disclosure-evasion structures. That is a question of legislative-reform priorities. It is not a partisan question.

The Federal Election Campaign Act (FECA) applies identically to both Americans for Prosperity Action's $548 million in 2024 cycle spending and to the Wyss-funded Sixteen Thirty Fund's $130 million in cumulative ballot-measure spending. The 52 U.S.C. § 30121 foreign-national bar applies identically to all foreign-national funders regardless of political coalition. The Wyss exposure on the ballot-measure-loophole question is more salient than any equivalent right-side exposure, but the framework applies in both directions.

The Foreign Agents Registration Act (FARA) applies identically to any 501(c)(3) or 501(c)(4) recipient of foreign-government or foreign-political-party funding that conducts political-advocacy activity in the United States. The statutory framework would, if applied vigorously, reach both the Tides Foundation's $47 million in 2024 grants to "undisclosed foreign recipients" and any analogous right-side fact pattern. The framework was never designed to be applied vigorously. It has been, historically, enforced against a small number of high-profile cases on both sides.

18 U.S.C. § 371 — conspiracy to defraud the United States, under the Hammerschmidt v. United States 1924 Supreme Court precedent — applies to any coordinated pattern of conduct designed to obstruct, impede, or interfere with the lawful functions of any federal agency or department. The framework reaches both coordinated state-AG counter-pressure campaigns against §4958 investigations and coordinated lateral-money-movement patterns designed to evade §6033 reporting requirements. The framework is the broadest available statutory hook for accountability against either architecture. It is also, historically, the framework prosecutors are most reluctant to invoke because of the operational complexity of proving the conspiracy element.

What all of this means, for purposes of Part Six's bipartisan-accountability commitment, is straightforward. The statutory framework is the framework. It applies symmetrically. If the framework gets enforced against one side and not the other, the result is selective prosecution rather than accountability. If the framework gets enforced against both sides, the result is bipartisan accountability. If the framework gets enforced against neither side, the result is the status quo ante — which is the architecture documented in Part Six and in this companion piece. The choice belongs to the federal regulatory and prosecutorial apparatus. The architecture is what it is.

What This Piece Is, and What It Is Not

Let me close this companion piece the same way I closed Part Six. The record shows the following.

• The right-side dark-money architecture, as documented in publicly available IRS Form 990 filings, FEC reports, state corporate-disclosure filings, and contemporaneous reporting from The New York Times, ProPublica, The Lever, CNN, The Guardian, OpenSecrets, and the Washington Post, is operationally parallel to the Arabella-Tides architecture documented in Part Six.
• The Marble Freedom Trust's $1.6 billion endowment, established through Barre Seid's August 2021 transfer of Tripp Lite stock to a 501(c)(4) organization controlled by Leonard Leo, is the largest single donation to a politically focused nonprofit in U.S. history. The transaction structure avoided up to $400 million in capital-gains tax that would otherwise have flowed to the U.S. Treasury.
• DonorsTrust, founded in 1999 by Whitney Lynn Ball as the right-side analog to the Tides Foundation, has moved over $1.5 billion in cumulative donor-advised contributions through a structure that preserves donor anonymity from the public record. The 2024 grants to America First Legal Foundation and America First Policy Institute total over $25 million.
• The Concord Fund and the 85 Fund, operationally rebranded in February 2020 from the Judicial Crisis Network and Judicial Education Project, operate the same fictitious-name pop-up structure under Virginia state corporate law that the Sixteen Thirty Fund operates on the left side. The 501(c)(3)/(c)(4) twinning, the multiple fictitious names registered for distinct political-fight purposes, and the same-building operational integration with the Federalist Society are documented in state and federal filings.
• The Schwab Charitable Fund pass-through route — through which the Marble Freedom Trust grants are routed before reaching the 85 Fund — is a structural innovation in donor-advised-fund laundering of the public-charity status calculation under §509(a)(2). The route preserves the 85 Fund's classification as a public charity rather than as a private foundation, which would be the classification triggered if the Marble grants were paid directly.
• The Charles Koch network — operating since 2019 under the Stand Together brand — raised $578 million and spent $548 million in the 2024 federal-election cycle, with $630 million in lateral pass-through transfers between Stand Together C4 Fund (zero employees), Stand Together Chamber of Commerce, Americans for Prosperity, and AFP Action.
• The Federalist Society's four-decade institutional infrastructure for Republican judicial nominations is the longest-running and most successful such operation in modern American politics. The Society is structurally integrated, through shared addresses and overlapping personnel, with the Concord Fund and the 85 Fund.
• The District of Columbia Attorney General's investigation of Leonard Leo, opened in August 2023 on a §4958 self-dealing complaint, has continued for over two years against a coordinated counter-pressure campaign by twelve Republican state attorneys general (organized through RAGA, which has received $20+ million from the Concord Fund and predecessors), the House Judiciary and Oversight Committees (where Concord Fund made its first federal PAC contribution in nine years one day after a subpoena threat), and conservative media (including Washington Examiner and Fox News stories targeting Schwalb on unrelated juvenile-justice policy).
• The same statutory framework — IRC §501(c)(3), §4958, §6033, FECA, FARA, and 18 U.S.C. § 371 conspiracy to defraud the United States — applies symmetrically to the left-side and right-side architectures. Whether the framework will be enforced is a question for the federal regulatory and prosecutorial apparatus. As of April 2026, the FEC is in its second quorum collapse with two of six commissioners seated. The IRS Exempt Organizations Division remains under-resourced. The CARES Act Oversight Commission ended its statutory existence September 30, 2025 with no chair ever appointed.
• Six asymmetries between the architectures are documented in this piece. Three run in favor of the left-side architecture having unique exposure (Wyss foreign-national funding scale, Newsom $187M public-money pipeline, coalition-operational overlap with federal-worker organizing). Two run in favor of the right-side architecture having unique exposure (concentrated single-donor structure, Federalist Society judicial-pipeline §501(c)(3) exposure). One asymmetry runs symmetrically (federal regulatory enforcement is structurally disabled across the relevant agencies for both political coalitions).

What this piece is not:

• A claim of moral equivalence between the left-side and right-side architectures. The asymmetries documented above are real. The Wyss foreign-national exposure has no right-side equivalent. The Newsom-Tides public-money pipeline has no right-side equivalent. The specific operational overlap with federal-worker organizing documented in Parts One through Five has its funder side rooted in the Arabella-Tides architecture and has no right-side parallel.
• A defense of the right-side architecture. The Marble Freedom Trust's $1.6 billion structure, the Leo-CRC Advisors §4958 exposure, the donor-advised-fund laundering route through Schwab Charitable, and the Concord Fund / 85 Fund fictitious-name pop-up architecture all warrant the same scrutiny that Part Six applied to the Arabella-Tides architecture. They have received less mainstream-media scrutiny than they deserve, and that under-scrutiny is itself a structural feature of the contemporary American political ecosystem.
• A claim that all dark money is equivalent in operational effect. The right-side architecture is more concentrated, more transparent in donor identity, more institutionally mature in its judicial-nomination function, and more directly accountable to a small number of named operational principals. The left-side architecture is more distributed, more obscured in donor identity, less institutionalized in its judicial function, and more diffuse in its operational principals. These are different architectures producing different operational effects in different contexts. The statutory framework reaches both. Whether enforcement reaches both is the open question.

The accountability test in American politics is whether the statutes get enforced against anyone operating these structures. That is the only honest accountability test. Selective prosecution against one coalition, while the other coalition's analogous operations continue undisturbed, is not accountability. It is partisan asymmetric warfare conducted through the statutory framework. American voters and American institutions deserve better than that, on both sides. The architecture documented in Part Six and in this companion piece deserves to be reached by the statutory framework. Whether the framework will be enforced — symmetrically, against both architectures, with equal vigor — is the question Part Seven of this series will walk in detail.

Part Seven is The Statute Book. It walks every applicable federal statute against the conduct documented across Parts One through Six and against the conduct documented in this companion piece. It does not distinguish between left and right. It applies the framework symmetrically. That is the only honest way to walk the statutory framework when the operational architecture is the same on both sides.

Part Eight is The Prosecutorial Road Map. It is the road map itself, for any citizen, state attorney general, federal prosecutor, or congressional investigator who wants to take the next step. The road map does not distinguish between left and right. It applies symmetrically.

That is what this companion piece commits to. That is what bipartisan accountability actually requires.

It's not the story they tell you that is important.
It's what they omit.

— Tore