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About MRFP, Inc. (NAAG/NASCO’s “Single Portal Initiative” for MultiState Registration and Filing by Charities — except, apparently, for MRFP, Inc, NAAG, and NASCO). Also See my New Page (publ. 11/11/17) on SimpleCharityRegistration.com [This post publ. 11/18/2017].

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Post Title: About MRFP, Inc. (NAAG/NASCO’s “Single Portal Initiative” for MultiState Registration and Filing by Charities — except, apparently, for MRFP, Inc, NAAG, and NASCO). Also See my New Page (publ. 11/11/17) on SimpleCharityRegistration.com [This post Publ. 11/18/2017](case-sensitive shortlink here ends “-7X8”).

Subtitle:  Who’s Regulating the Regulators? Why are they exempt from the rules they exist to enforce?  Wake Up, People!!

Those Acronyms in the Title:    “MRFP” = (see post title).* “NAAG” = National Association of Attorneys General.  And “NASCO,” it’s said, is “National Association of State Charity Officials.”**

  • *Technically speaking, “MRFP, Inc.” is a business name, not an acronym, but it does seem to represent the phrase”MultiState Registration and Filing Portal.”
  • **“Proof of Life” or business entity personhood is just not found so far, despite other similar or interested entities, even the IRS.gov itself, publicizing, positively, the name in full and as an acronym as if a creditable point of reference and a legitimate entity with a legal domicile somewhere in the USA or one of its territories.
  • **If so, if NASCO exists, where is its incorporation or charitable registration; does it even have an EIN#? If yes, then where are its tax returns or even a single Form 990-N?  Or where is it on someone else’s tax return as its fiscal agent?  
  • **…Speaking of which, I’d ask NAAG (i.e., a NAAG Tax return/Form 990) which seems to be acting as a fiscal agent for some NASCO functions — but where are NAAG’s returns (even though NAAG’s EIN#, no thanks to NAAG’s own website, was eventually found)?? 

For an example of references to NASCO (as well as apparent confusion, as ever, between the puppet and the puppeteers, that is, the creation and the creators — specifically a business with a product, and the product itself), these next two links to a single document written as if responding to the “RFI” (Request for Information) on the Single Portal Initiative, showing the logos for “GUIDESTAR” on the left and “SimpleCharityRegistration.com” on the right, and the found document was actually posted at MRFP, Inc. …

By the time you get through my page on this, you’ll see that SimpleCharityRegistration.com also adds fully FOUR logos labeled “in partnership with” of which one is Guidestar, and another one (BizFilings.com) provides us clues to the whole mess that predates the federal income tax, and how corporate law was adjusted (and by whom) to get around anti-trust laws of the same era. It’s fascinating information and definitely turned on some of my own lights as to the phenomenon I’d already observed of effective monopolies (or “oligarchies”) within the nonprofit sector and intersecting with government itself.

I also discuss several aspects of that situation here, adding some new links.

Annotated: RFI response to MRFP by GuideStar and Simple Charity Registration (4pp, p1 only shown)  My many annotations highlight the troubled verbiage found at a RFI posted at MRFP, Inc.  What’s more, that pdf seems immune to being displayed as an image other than directly from the website (meaning, if the link changes, “too bad.”).. Please do click that link and read my annotations … The annotations make for a visually cluttered page but still raise ongoing and important questions about the language.  I question whether anyone who could produce and would even think it appropriate to post a mess like this should be taken seriously when the topic is organizing and monitoring charitable entities (!!).  Apparently some corners (lots of them) have been cut in putting up a show of fair usage of the funds involved for such a project.

Plain: Link to a clean copy, all 4 pages, posted at MRFPinc.org under “Request for Information” and apparently from this and other context dated sometime after 2015 or 2016, although it’s not actually dated (or signed) within those four pages, at all. One of the companies mentioned on it, I still haven’t found.


On 11/11/2017, after some days of rapt attention to this new area of learning about how many different ways (and how many red flags along the ways) government employees of high rank and authority over and responsibility to regulate major parts of the private sector can and so often do form private-sector corporations, boasting among each other and on the private-sector corporate websites (which many of the public may never stumble across, ever…) about the public benefits for the project — and doing this all while withholding/concealing identifiable registration of the same private-sector (tax-exempt of course), or failing-to-file, and/or failing-to-file-IRS Forms 990 even when they may have registered,* and in general thus distracting the public from one of the most critical things that public deserves to know,** I published a new page containing a helpful list, alpha by state, of where charities have to register…unless they don’t because for some reason they’re exempt.

Page Title: State-by-State Charity Lookup Links (from SimpleCharityRegistration.com’s March 2017 WordPress post)   Started Nov. 8, 2017, Published Nov. 11; intended for my “Vital Links” sidebar menu. Case-sensitive, generated short-link ends “-7Vm”       Recommended — read that Page before this Post for better statement of context.


Without a glossary of organizations and sense of who they are and how they interact, and some examples of how they speak and act (for “act,” I’m talking filing accountability and transparency issues, absence or presence of double-talk, or promoting what may (and sometimes sure seem to be acting like) fake-name persona (repetition of reference among the community substituting for actual registration and production of tax returns, or a declaration why there are none), this gets complicated.  [The complication on the part of above-named organizations seems intentional.]  I’ve been studying this situation for about two weeks (with the new page, which unfortunately doesn’t show automatically on blog “Archives” calendar, published Nov. 11, mid-way), processing information and considering whether it fits with or contrasts/challenges my existing understanding (skepticism) about the field as a whole.

Showing this with exhibits, typically each exhibit becomes its own section, takes some time. I repeat some of the above paragraphs (this post title + acronyms; the paragraph introducing new page title /yellow background) below to help with continuity. //LGH.


This topic takes precedence over follow-up posts which I’d promised recently because it is so current and the issues it signifies so weighty. I also gather this project is probably not reported much outside the government and philanthropic circles (with mutual self-interests on both parts), and on their respective journals, newsletters or “Gazettes” posted on websites.

This post also generated its own follow-up list of three.  In order of writing:

  •  Upcoming, based on my recent check-in with The Urban Institute Form 990:
Title:  A Year In the Life (2015, the latest available from this perspective) of a VFTT (Very Famous Think Tank), through its IRS Form 990 Tax Return. (shortlink ends “-7Xz.” Post begun Nov. 13, 2017).This VFTT entity’s address can be seen in the URL domain name to a one-page, Sept. 2015 description of the Single Portal Initiative and MRFP, Inc. (as “working with” the NAAG/NASCO combo).
  • Then, on another mega (well, large and prominent) foundation in New York, I wrote:  Verrry interesting. It’s a whole other category of “out-there” “You’ve GOT to be kidding!” information and presentations, again, demonstrating how those already IN nonprofit board (or even major program — as in involving decisions on grant-making) power circles manage to spread their roots, quickly transplant operations if deemed a good idea, and seeking to standardize nonprofit measurement globally — while at home, leaving BIG gaps in accountability and transparency on their various organizations… And, I off-ramped it, except just two images to support a reference in the title.  See next five-line post title:
  • and, from RHF, above, tracking just two nonprofits associated with just one of its prominent (“star-studded” might be a better word) board of directors, and one of the nonprofits’ recent contractor, “Blessing White,” where “Blessing White Courses” generated $766K revenue in a single year (FY2015) for the entity, and obviously some certification/ replication / global consultancy with on-line deliverables was involved.

Looks like [Jeffrey] Immelt went straight from Harvard MBA (after a BA/BS from Dartmouth in Applied Math) to GE and hasn’t left yet.  Meanwhile he sits on a variety of foundations, a seat at a White House Admin table (this quote is as of Oct. 2016, obviously before changeover of White House Administration to President Trump), and the Business Roundtable.

[See off-ramped post currently called]: Catalyst Inc, Blessing White Courses, GP Strategies (Global PIC*), GSE Systems, and the Ronald Reagan Presidential Foundation. (*PIC = “Performance Improvement Company”) (shortlink ends “-7YU,” moved here Nov. 17, 2017, cf. Jeffrey Immelt, director of Robin Hood Foundation, a single drill-down on just two nonprofits mentioned from his Bloomberg.com profile….).

Those are the three posts that this one inspired (sections already written in the process of writing it) but for which length restrictions and focus considerations got them bounced off.  The process for each is similar and basic but always time-consuming: I look at the financials (typically mostly the 990s but sometimes also a financial statement, if one is available) and talk about them, comparing sources of revenue, expenses, assets accumulation over time, and sometimes in what they are declaring investments. …. I look at related entities if shown, and connect with other available information on either the directors, or corporations mentioned in them, I compare.

I do not subscribe to Nonprofit Quarterly, Circle of Philanthropy or similar journals (I do to “Institutional Investor” magazine and I also read the paper versions of The Wall Street Journal regularly, and The New York Times, some), but it’s my impression that what I talk about here, in “lay terms” for the general public, they do not. They (such publications targeting the philanthropic sector, whether seeking grantees or grants, or both) also don’t even seem much concerned about the discrepancies regularly found on Forms 990 within and between organizations except as it might discredit the sector and impact: jobs, social status, and the status quo.


Significant elements of the philanthropic and government (private/public) sectors say they have been collaborating on the “Single Portal Initiative” to better streamline, establish and facilitate the rapid increase in filings by the nonprofit sector, already a significant “player” in (influence on) the national and international economic landscapes.  Allegedly this is “the better to monitor them with” also…

And for those who happen to subscribe to philanthropic journals, either looking for grants, grantees, or seeking to align policies for outcomes, and in competition for donation dollars, there have been some articles also.  These journals seem to feed off each others’ energy and optimism, regardless of poor results for some project being promoted, synchronously, among them.

Here’s an article in such a journal commenting on how hard the project must be, since after receiving Department of Commerce Funds for it in 2003, a follow-up “Request for Information” didn’t surface from one of the recipients until 2016!  The article provides more clues to in what direction the credibility crisis on tax-exempt organizations for those who do pay attention, will be, and is being as we speak, leveraged. Please click annotated text image below to read some of the terms in context I will be bringing up repeatedly in this post (and also do on the page):

Nonprofit Quarterly, Summer 2016, 8/11/2016, The Rising of the States in Nonprofit Oversight by Lloyd Hitoshi Mayer, from another article in same publication called  “The New Nonprofit Regulatory Environment: What You Should Know” article (graphic + title only).  Notice my warning “only 3 free articles remaining.”

excerpt from Nonprofit Quarterly, Summer 2016, 8/11/2016, The Rising of the States in Nonprofit Oversight, 8/11/2016, by Lloyd Hitoshi Mayer. Notice references to NASCO (1979), US DOC funding in 2003 to NASCO/Guidestar (another 1995ff highly profitable (program service revenues) nonprofit providing a subscription database of nonprofits, or much less information in less flexible format, for free) for the Single Portal Initiative and to a “National Attorneys General Program at Columbia Law School, (NY) working with the Urban Institute, yet another nonprofit known (in part) for its own charitable database (formerly NCCS.dataweb.urban.org).

Only after I did discover the “Single Portal Initiative” looking for the charitable registry of a single state and discovering a list of on-line registration links alpha by state (in states where registration is required, that is), did my more targeted search phrase bring up more material on it and patterns start surfacing; not always the patterns which were being reported on, however.

Did you know that Columbia University’s Law School had a National Attorneys General Program, or than an entity called NASCO is alleged to exist (and whether it does or not?  I’m still looking!).  Is it not a little odd that those reporting on the above information using the FTC’s and unified state attorneys’ general (probably unified via NASCO / NAAG meetings) recent victory over two sham cancer charities becomes a “clarion call” to change the IRS oversight of tax-exempt charities, possibly privatizing it?  Another article — footnoted above — by Lloyd Hitoshi Mayer (also in 2016) proposes this, and makes little mention of why thirteen years of not even an “RFI” after government funding to a NASCO/ Guidestar collaboration is evidence of competency?

Do you feel that the privatization should involve private associations named after public state-level offices which such as NASCO, NAAG (National Association of Attorneys General) who do not post their tax returns (although they seem to be private) on their websites, even in response to their own “FAQ” labeled “Where does it get its funding?”….

I found it odd but relevant (when size and scope of operations is considered) that the top of this article starts out mentioning the cancer charity sham (so does the website NASCOnetSupport.org, apparently the result of the collaboration mentioned above) and the first two footnotes are to that victory.

The third footnote is another article (recommended read!) by the same author, but this time in a Columbia Journal of Tax Law, and apparently part of a Univ. of Minnesota symposium.  It raises the question, and proposes possible answers, to how should the poor (lacking the resources for oversight), reputation-recently-battered-by Congress and the media, IRS reign in the bad charities and preserve the domain for the good guys?  I don’t agree, but it’s well-written and informative.  I suggest reading it, and noting the timeline of even requiring charities to register, and how very recent (2006) the practice of even revoking those who refuse to file three years in a row, are good to know (and that information should also be validated; I haven’t…).

The introduction sets the stage for saying, the IRS just isn’t up to regulation, and I’ve posted links to the concluding sections (a radical alternative) IV and V. Note: this is copyrighted material which can be read on-line and there is as you can see a downloadable link for full text:

 

Hitoshi-Mayer I see has been with Notre Dame since 2005, and in the capacity shown here (Nonprofit Executive Certificates offered), and that he’s Stanford (1989) followed by Yale Law School (1994):  https://www.notredameonline.com/programs/faculty/nonprofit-executive-faculty/lloyd-hitoshi-mayer/  For only $1,980, you, too, can (presumably) take the only two courses listed where he’s subject matter expert:

…Professor Mayer’s areas of research interest and expertise include advocacy by nonprofit organizations, the growing intersection of election law and tax law with respect to lobbying and other political activity, and the role of nonprofits both domestically and internationally.

Subject Matter Expert in

Here’s another published in “America” (“The Jesuit Review”) Sept. 3, 2015, “Churches and Taxes: What John Oliver Got Wrong (and Right)” It’s short and professionally courteous to the late-night TV host whose staff set up an “Our Lady of Perpetual Exemption…”
I appreciate the good (better than average for sure) writing, but coming from a different perspective –having dealt as a client with various nonprofits (surrounding domestic violence and the family courts, and economic fallout around the same, overlapping with curiosity enough to look up the networks and take notes along the way, not as an advocate FOR these systems, but to learn about how they was put together and funded — I also notice what’s been omitted along the way, consistently, and not just by this writer in the articles shown above.

Some of my (rhetorical) questions follow. I’m wondering why these aren’t also being raised by the various journals and philanthropic publications, except for the tendency to assume that ongoing expansion, being the current status, should continue forever as the causes of “the good guys” among the tax-exempt are so noble.

For example, a current article on Nonprofit Quarterly implies that the nonprofits are the proper “mediating structures” between government and the public, and for teaching people how to function in a democracy, and how to organize.  

If so, that’s a shame, as nonprofits obviously can be bought and sold according by their sponsors are in competition within a system which itself facilitates money-laundering [running profits from crime through unaccountable business registrations, even legitimate ones] through a built-in, mathematically, statistically self-defeating sort of formula (I’m not a mathematician, so don’t let this offend those who are.  But, think about it:)

Most people’s resources are limited, whether to their jobs, pensions, or other household income.  In addition, the only “unlimited” factor in producing ongoing tax receipts is human reproduction:  creating more wage-earners and workers. By contrast, the quantity of existing nonprofits and potential to create more endlessly (being encouraged through this “Single Portal Initiative”) just about unlimited, especially if considered over time (some disappear, change names, others re-appear, they merge, with disappearing and surviving entities just like for-profit businesses, and almost any once can under cover of its Form 990 filing house many “Related entities” (Sched R in the newer Form 990s), whether category “disregarded” “Tax-exempt” or “Taxable” in two different categories (i.e. Sched R Pts. I, II, III and IV). In addition, there is the matter of subcontractors — how many (there seems no limit) — per nonprofit?  That multiplies the effect and the factors to be monitored IF nonprofits are to be monitored.


In addition, there are those exempt from filing in the first place, whether because religious or for other specific reasons. (See Columbia Journal on Tax Law Article; estimates of this sector are included in the “The Better Part of Valor…” article)

If the nonprofits existing to help people (and operating with tax privileged status because they do so — are to be monitored, it’s the people (specifically, employees, taxpayers) who will end up paying even more to monitor (without likely ever doing so effectively).

(Click image to enlarge for article abstract or intro as shown). This dates to 11/17/2017 and is seen on “nonprofitquarterly.org” home page: Lead-in text is: …Long recognized as “mediating structures” nonprofits have a fundamentally American role in helping to organize and educate the population for civic action and engagement, and indeed, to teach individuals the very basic skills of democracy itself.”

Many nonprofit organizations have, at their core, a mission to enact social change—whether that’s ending homelessness, supporting access to healthcare or other services, or serving vulnerable populations. Yet, it’s obvious to many of us in the nonprofit sector that the communities we serve are feeling the direct impact of the current political climate.The debates on hot-button topics like race, religion, immigration, healthcare, and the environment, to name a few, are leaving nonprofit clients and other stakeholder groups feeling scared, persecuted, further marginalized or afraid to seek out the very services nonprofits are offering.

In addition, funding for important programs hang in the balance, grant programs are being eliminated or redefined, and much needed legislation and appropriations are being held hostage by both state legislatures and the US Congress. The President and Congress have also suggested policies that may directly impact the ability of the nonprofit sector to fundraise, including proposed changes in the tax code that would eliminate the charitable deduction for more donors.**

If any single sector is going to help respond to these critical debates and bring people together, it will be the nonprofit sector.


(**”Thanks” for a link to a CNBC.com article that was broken as of one day after publication, and which “Page Not Found” link somehow reads 2012″ while the Nonprofit Quarterly link dating to it has the date May 22, 2017 in its url, even though this seems a key point in the article.)

  1. While nonprofits may and often do wish social changes, as a sector one thing they all wish is to attract money through functioning tax-exempt status themselves, and continue attracting contributions tax-reduction for donors, and retaining enough contributions to continue qualifying for tax-exemption as a public-supported organization.  This is a privileged status in the US; and it’s fair of me to say another thing nonprofits “want” is to retain their privileged status while being credited with saving the poor and vulnerable, if not society itself.  Meanwhile, the sector has the most to gain in terms of retaining control over its wealth without starting riots over it  (i.e., with their reputations pretty intact) through reducing taxes on the empire, and persuading the public that government is its partner, and should continue to accommodate AND sponsor grants and contracts throughout the nonprofit sector, are indeed the wealthiest individuals and families around.

It really doesn’t take THAT much time looking at Forms 990 or Forms 990PF to figure that out, either..   Some (of course) not all of the dramatically privileged salaries involved in some of the better-funded ones, i.e., those that “go along with the crowd” as foundations…But I don’t think Nonprofit Quarterly exists in order to encourage rank-and-file people to make a habit of looking at tax returns…

Do you think the tax-exempt sector, private, should be privileged to regulate itself without divulging the background of the regulating entities behind this move in the first place? Here’s the conclusion of the Nonprofit Quarterly 2016 article above; footnote 3 links to an article by the same author in 2016 Columbia Journal of Tax Law suggesting that the IRS’s time for regulation might be over, and a better way is possible — private “SRO” (Self Regulating Organization) with IRS oversight.  The article is well-written (Hitoshi Mayer writes as  Notre Dame University (IN) professor — of what, not shown — and other articles in the same journal, particularly on history of the income tax (the Brits preceded the US in this) all look like good reads.  I have started….

Opening and concluding paragraphs with (only) 3 footnotes from Nonprofit Quarterly, Summer 2016, 8/11/2016, The Rising of the States in Nonprofit Oversight by Lloyd Hitoshi Mayer

In an extraordinary development, all fifty states, the District of Columbia, and the Federal Trade Commission filed a federal lawsuit in May 2015 against four charities and their operators, alleging that they had defrauded more than $187 million from donors.1 While the dollar amount was staggering, the most unusual aspect of the lawsuit was the incredible level of cooperation among state nonprofit regulators. This cooperation was evident not only in the bringing of the lawsuit but also in its successful settlement less than a year later, with the defendant charities and their principal officers surrendering substantial assets, agreeing to dissolution of the charities, and acquiescing to being banned from fundraising and management of charities and charitable assets in the future.2


The bottom line is that nonprofits need to be aware that even as IRS enforcement of the federal requirements for tax-exempt organizations continues to be battered by limited resources and congressional criticism, the states have quietly laid the groundwork for more effective individual and collective oversight of nonprofits. That groundwork is starting to bear fruit, as illustrated by the recent multistate lawsuit, the renewed Single Portal Initiative, and the NAAG Charities Committee, as well as the addition of increasing governance obligations to the nonprofit laws of California and New York. Nonprofits, therefore, must be sure to treat compliance with their state legal obligations as seriously as compliance with their federal tax obligations, as well as making sure to keep track of the ongoing state law developments that could impact them in numerous ways.

Notes

  1. Federal Trade Commission, “FTC, All 50 States and D.C. Charge Four Cancer Charities With Bilking Over $187 Million from Consumers,” press release, May 19, 2015.
  2. Federal Trade Commission, “FTC, States Settle Claims Against Two Entities Claiming to Be Cancer Charities; Orders Require Entities to Be Dissolved and Ban Leader from Working for Non-Profits,” press release, March 30, 2016.
  3. Lloyd Hitoshi Mayer, “‘The Better Part of Valour Is Discretion’: Should the IRS Change or Surrender Its Oversight of Tax-Exempt Organizations?,” Columbia Journal of Tax Law 7, no. 1 (2016): 80–122.

 

{{BLOGGER LGH COMMENTS:  There are more footnotes.  All emphases in main article quoted above are added.  Please click and at least briefly skim footnotes 1, 2, and 3 <=(read abstract and intro, plus header info) for better understanding of the context of this post. Remember that the FTC didn’t have authority over tobacco or tobacco products until the “Tobacco Control Act” of 2009, which I’ve posted on, and that before that, attorneys-general united (class action) litigation against “Big Tobacco” companies (and a trust) in the 1990s resulted in a massive settlement in 1998 (the “MSA”) and with it, massive windfall to the states which was housed, as I understand it, in “American Legacy Initiative” which was since renamed “Truth Initiative Foundation” (“TruthInitiative.org”), and from this some more massive tax-exempt foundations were birth, and fed.  The litigation continues.  Also remember the website “smokershistory.com” challenge to the whole apparatus and the “Lasker syndicate” to beef-up the NIH and HHS funding for biomedical research on smoking as the cause of cancer, and that among the 50 largest charitable foundations (Forbes list) are several the Laskers were involved with.  etc.  

In this light, and in light of the poor, and barely complete quality of the resulting website “NASCONETsupport.org,” and the more than evasive one of the website for the NAAG, I have a rather different interpretation on why there was such a uniform glee over catching some of the competing Cancer charities at their own game and publicizing it, shutting it down.

I hope this shows that within and among the nonprofit sector, these things (movement to shift to state regulation of charities over the IRS, Single Portal Initiative, and triumph over the fake cancer charities involving (check it out) ironically a family with the last name “Reynolds,” are getting major discussion, but in other places, they are not under “in your face” discussion.

Meanwhile print, cable TV, and on-line news media continue to cover and feature interviews about US Congressional (House, Senate versions) presumably budget legislation advertising or protesting the impact of major “tax reform” as usual, with next to no mention on the impact of this major and ever-growing (some, growing big and fat, or at least chewing through contributions as fast as they come in (i.e., ever-ravenous), and rapidly proliferating its own kind) nonprofit sector as a sector on everything from jobs, to collective government receipts — and to the social and cultural landscape of the country.  While the philanthropic, private, tax-exempt sector is distinct from government itself, the lines seem increasingly blurred, and making a clear demarcation is, it seems, frowned upon.

Certainly the nonprofit or “philanthropic” sector is mentioned positively when considered as part of a welfare safety net, or, subsections of it negatively in Left v. Right politic exposes– then specific nonprofits on the opposite political spectrum are reported for inappropriate influence on government, or setting up shell organizations, but I’ve yet to see it mentioned seriously and consistently (front page or featured) in the “mainstream media” as a sector affecting distribution of wealth, and as reducing of potential government receipts / increase of government expenditures.

More tax-exempt entities doing business, funded privately and/or by government, either way = less tax receipts by sheer definition.  The general structure has been in place now for it seems at least a century (1913-2013, minimum), so questioning this may be seem like sacrilege — but I still do.  The more 990s I read (or cannot locate!), the more I question the whole concept.  

This philanthropic sector is major and significant not just in size of assets, often in individual privately controlled, tax-exempt foundations, and as collectively held, exchanging a minimum number of charitable distributions each year for significantly reduced taxes on “noncharitable use assets”– judged by normal standards (household, even individual families’ wealth), but also ultimately in how untraceable those assets (let alone revenues & expenses) are in whole, and even in parts. It is a privileged sector not just by way of tax exemption and write-offs, but also by way of privacy of operations allowed by the IRS forms themselves (for example, only requiring 5 subcontractors to be listed when sometimes the total number may be 15, 20, 50 or more un-named sub-contractors). One example; for more look for Part VIIA on a standard Form 990 (not “990F”) for any large charity:

IRS Form 990 doesn’t require listing of excess subcontractors by name, type of service and amounts paid after the first 5. Here (RHF FY2008), that meant over ⅞ of the subcontractors claimed were NOT named. Nor does it show an average amount, or the total amount — although this form easily could’ve prompted for this information. Therefore — if it doesn’t show, who’s to know? whether the figures are always genuine?

The nonprofit sector is also major when it comes to leverage, to privatization, and to facilitating the concentration of wealth in the hands of those who historically held it while promoting the cause as doing the opposite, redistributing it to the poor.  Speaking of which, there is even a “Robin Hood Foundation” as if the main characteristic of its redistributions were taking from the rich and giving to the poor.  A closer look shows other, less savory and more questionable, characteristics…and not just on this single foundation.

[[Verrry interesting. It’s a whole other category of “out-there” “You’ve GOT to be kidding” information and presentations, again, demonstrating how those already IN nonprofit board (or even major program — as in involving decisions on grantmaking) power circles manage to spread their roots, quickly transplant operations if deemed a good idea, and seeking to standardize nonprofit measurement globally — while at home, leaving BIG gaps in accountability and transparency on their various organizations… And, I off-ramped it, except just two images to support a reference in the title.  See next five-line post title:]]

Supporting my concerns re: (1) the “disregarded entities/Ponzi Scheme” and (2) an at least $3M discrepancy between grants reported, and grants reported received (same fiscal year) the bolded part of this title (the other parts, while written-up and cited to, are still under (my) investigation.  Right now, it seems to be…

Robin Hood Fndtn’s YEDec20115 Sched R Pt I DISREGARDED ENTITY ROBIN HOOD HOLDINGS (Sched R Disregarded entity) (shown w|o any suffix indicator and possibly a wrong EIN# (same as the 501©3’s offered) from its website.

Placeholder for a missing thumbnail, RHF leadership page

Sched R Disregarded Entities from earlier RHF Form 990 (2008?)

FY2003 Disregarded Entity Section (Pre-2008, in a diff’t part of return) for RHF, showing Robin Hood Holdings LLC described as “2001 Relief Effort.”

cf. Robin Hood Holdings etc Securities Fraud, FACKRELL (Erezlaw’com website). I am still looking at this situation, a direct connection to the RHF has NOT been established, although one of their disregarded entities has one of those names… Note: The potential exists until disproven that there might be either a direct connection, or a coincidence in overuse of the well-known reference to Robin Hood as part of legal entities’ names…

Single Stop USA FY2008 return (from “990finder”) showing a discrepancy of about — actually, a minimum of about– $3M between what RHF claimed to have donated TO Single Stop and what it acknowledged receiving (see RHF 990, FY2008 Sched I Grants, next image below).

RH Fndtn EIN#133441066) FY2008 (<==link to the entire return) (YE Dec) — Reports $11.6M to a 2007-formed SingleStopUSA entity, which only acknowledged receiving $8M the same year (also YE Dec, see prev. image). SingleStop USA went from “0 to 60” financially in a single year, and has (though not acknowledged til recently) a disregarded entity (software) for signing up people for as many government benefits as possible, efficiently, in multiple states (Tax, Benefits, Healthcare, Legal counseling) and admits (FY2008 Form 990) to having taken over RHF’s NY sites for this purpose.  

In 2008, that $11.6M was only around 10% of the $110M in grants distributed that RHF claimed.


Also, I thought you might like to see some of the famous people on the board (a few images, mostly volunteers) and — moved to the BACK of the return after the pages of grants, although the continuation page showed it could easily have been placed in order (where it belongs) as part of the return proper — the list of salaries paid to Officers, Key Employees, and Highest Paid Employees (incl. Michael Weinstein, $445K + benefits) for the RHF.

If my organization’s main theme of a sponsored organization was “slashing poverty” and “Poverty Is Complex” (which both these entities declare on, respectively, 990 exempt mission purpose, and home page of website), then I too might want to downplay how many staff are pulling in compensation from a quarter- to a half-million dollars a year, let alone in the mid $150K range –  (and that the entity is itself nearing a half-billion gross assets, of which $114M are in “alternative investments — limited partnerships,” … or that somehow it made $8M profit on selling securities and the same year, posted a deficit of about the same on the REVENUES page under direct expenses (after contributions) for fund-raising…

RHF FY2008 Page 1,* Line 13 shows total grants distributed this year. Compare to Total Gross Receipts (near top) or Revenues (Line 12).  (*Link is to the entire tax return)

RHF Fndtn FY2008 Board Members (all these unpaid) incl. Tom Brokaw, Marion Wright Edelman (founder of the Children’s Defense Fund), Geoffrey Canada (well known for Harlem Children’s Zone) and others whose last names include “Jr.,” “II,” or “III.” Or see Jeffrey R. Immelt (ca. 60 yrs old) per Bloomberg.com (Chairman of GE since 2001, and Executive Director until recent stepdown..Trustee of Dartmouth since 2008, NBC, etc. (see quote, dark-green background, nearby)

Second page of volunteer directors, showing Grand Total for this Part VIIA was over $3M + benefits.

@2017, Michael Weinstein reported also as Chairman of “SingleStop USA” (which in 2008 got an $11.6M startup (Yr 2 of its existence) grant which its own tax return doesn’t acknowledge) and, per RHF foundation, “impactM.org” and “Circle of Philanthropy news (3/17/2017) is also CEO of new nonprofit “ImpactMatters” registered in CT only July, 2015

Here’s from just one of the RHF directors for the year where at least $3M seems to have gone “MIA” (and that’s only referring to the ONE connection out of over $110M in grants I happened to check because it was the largest): Jeffrey Immelt, per Bloomberg.com (see caption, also “as of” date on Bloomberg. Color scheme and ALL emphases (and any paragraph breaks), added):

Mr. Jeffrey R. Immelt, also known as Jeff, served as the Chairman of General Electric Company (GE) since September 7, 2001 and as its Executive Director of General Electric Company since 2000 until October 02, 2017. Mr. Immelt served as the Chief Executive Officer of General Electric Company since 2001 until August 1, 2017. Mr. Immelt served as the Chairman and Chief Executive Officer of General Electric Capital Services, Inc. He served as the Chief Executive Officer of General Electric Capital Corporation (a/k/a, GE Capital Global Holdings, LLC). He joined GE in corporate marketing in 1982. He held a series of leadership positions with GE Plastics in sales, marketing and global product development. Mr. Immelt served as Vice President of GE since 1989, responsible for consumer service for GE Appliances and then as Vice President of Worldwide Marketing & Product Management for GE Appliances since 1991, Vice President and General Manager of GE Plastics Americas commercial division since 1992 and Vice President and General Manager at GE Plastics Americas since 1993. He served as Senior Vice President of GE and President and Chief Executive Officer of GE Medical Systems from 1996 to 2000. He has been the Chairman of GE India Services Holding Limited since September 2001.

Mr. Immelt served as Chairman of Baker Hughes, a GE company until October 02, 2017.

He has been a Trustee at Dartmouth College since September 2008. He serves as a Director of NBCUniversal Media, LLC and NBCUniversal, Inc. He serves as Trustee of Ronald Reagan Presidential Foundation Inc., The. He serves as a Director of Catalyst Inc. and of Robin Hood [Foundation??]. He served as Director of The Federal Reserve Bank of New York from January 2006 to March 2011. He served as Director of General Electric Capital Services, Inc. He served as a Director of General Electric Capital Corporation (a/k/a, GE Capital Global Holdings, LLC) since 1997. He serves as a Director of Robin Hood Foundation. Mr. Immelt serves as a member of the President’s committee on American manufacturing. He serves as Member of Executive Committee at The Business Roundtable. Mr. Immelt served as the Chair of President Obama’s Council on Jobs and Competitiveness. He was named the Financial Times “Man of the Year” for 2003. He was named one of the “World’s Best CEOs” three times by Barron’s. Mr. Immelt holds an MBA from Harvard University in 1982 and a BA/B.S. Degree in Applied Mathematics from Dartmouth College in 1978.

Ronald Reagan Presidential Foundation & Institute (latest tax return shown, FY2014 only):

(Miscellaneous from 990-survey, quick look only: Founded in 1985; interesting analysis of where they are, and are not, making the income over time) (Doing better at marking up inventory sold and charging really high prices for admission, including apparently to school kids, and (smaller amounts) as a landlord then at profits from sales of the ongoing substantial investments, although there are plenty of subcontractors and a well-paid (ca. ½ million salary) CEO, plus famous trustees such as Rudolph Giuiliani, Peter Wilson (presumably the Pete Wilson), Rupert Murdoch, etc.).

Total results: 3Search Again.

ORGANIZATION NAME ST YR FORM PP TOTAL ASSETS EIN
Ronald Reagan Presidential Foundation CA 2015 990 50 $286,799,196.00 77-0054631
Ronald Reagan Presidential Foundation CA 2014 990 40 $292,433,726.00 77-0054631
Ronald Reagan Presidential Foundation CA 2013 990 50 $274,624,096.00 77-0054631

(I also just looked up “Catalyst, Inc.” and confirmed (prior years) Mr. Immelt was on its board (1h/week volunteer). It was formed 1962, legal domicile Ohio with a “120 Wall Street NYC” address and, while moderate in size compared to, say, the Robin Hood Foundation (!), it’s still $27M Gross assets.  It shows several related organizations taxable as corporations (Sched R Pt. IV) in four or five different countries (increased over time) and at one point had a Canadian nonprofit also.  Again, on Catalyst, it’s a FY2015 subcontractor Blessing White that interested me, although I did look at several years’ tax returns (skimming for content) and the website itself.

Content Off-ramped Here re: Catalyst, Blessing White, GP Strategies (a global “Performance Improvement Company”)

[See dark-green-background quote from Bloomberg.com, above] Looks like Immelt went straight from Harvard MBA (after a BA/BS from Dartmouth in Applied Math) to GE and hasn’t left yet.  Meanwhile he sits on a variety of foundations, a seat at a White House Admin table (this quote is as of Oct. 2016, obviously before changeover of White House Administration to President Trump), and the Business Roundtable.

The new home of that section currently called: Catalyst Inc, Blessing White Courses, GP Strategies (Global PIC*), GSE Systems, and the Ronald Reagan Presidential Foundation. (*PIC = “Performance Improvement Company”) (shortlink ends “-7YU,” moved here Nov. 17, 2017, cf. Jeffrey Immelt, director of Robin Hood Foundation, a single drill-down on just two nonprofits mentioned from his Bloomberg.com profile….). Currently in draft. Link above active and accurate when it’s published. Til then it’s active (but only to WordPress’s “best-guess” alternate post).


The two different characterizations of “Robin Hood” and “Robin Hood Foundation” makes me wonder if this is just a casual difference, or representing two different entities (all the GE ones are named precisely, it seems).  Re: the Financial Times (I believe that’s a British-owned publication).

Separately (and no indication yet, related to the foundation) there is also a Robin Hood Holdings, Ltd. involved (around the 2009ff timeframe) in the pharmaceutical industry which had SEC involvement ensuring there wasn’t a monopoly being formed on certain generic drugs.  Meanwhile, the RHF tax return for 2015 referenced “Robin Hood Holdings” MINUS any suffix (such as LLC), but given the state of incorporation (Delaware), it seems to have been an LLC — but also fed the readers a fake EIN# (same as the filing entity — which isn’t possible if there are actually two different entities, as the form is saying), while on earlier tax returns, which DO include the suffix “LLC” with “Robin Hood Holdings,” the suffixes (LLC) are shown — but, although the IRS form clearly says “Name and EIN#” — none were supplied.  That year was 2008.

That’s not all the “avoidance” or “Just couldn’t be bothered” filing behaviors showing up, particularly on Single Stop USA, Inc. (focusing on streamlining benefits sign-ups; an other part of the RHF board member and staff member proclivities).. But telling it will take more time.

The Robin Hood Foundation Forms 990 says it started in 1988, two years after major change in the Internal Revenue Code, and the 1980s known to be a time of corporate mergers, LBO’s (<== Wiki) coming into their own; also a decade culminating in the savings & loan bailouts.

Major positive cash flow for some**  ==> need for reduction of taxes also — although the cash flow representing interest on debt (to the powerhouse/buyer corporations) — represented some reduction in taxation [[**major negative in the form of job destructions to increase profits pay for the debt incurred by  the LBOs for others]]:

3 reasons the go-go 80s aren’t back on Wall Street Oct. 20, 2015, in Fortune, by Stephen Gandel

…LBOs were the deal on Wall Street in 1980s. Between 1979 and 1989, there were over 2,000 of them worth $250 million or more. But these days, huge leveraged buyouts are not the norm. In the years since their heyday, LBOs have been described as huge, selfish and job destroying.

But that’s not how they were seen some 30 years ago. In the early 1980s, Carl Icahn, T. Boone Pickens, Irwin Jacobs, and other corporate raiders actually claimed the moral high ground. They said they were there to do what other investors hadn’t. Their role, they said, was to hold management’s feet to the fire, break up inefficient businesses, and save the American economy. The 1970s had hatched plenty of large lumbering conglomerates, so it seemed like Icahn and others had a point.

Junk bonds too were new, pioneered by the now-defunct Drexel Bernham Lambert. Michael Milken built a money machine based on debt and deal making. Without the junk bonds, LBOs couldn’t get done. And without big LBO deals there would be no junk bonds. So Milken threw a high-powered get-together for the corporate raiders every year. CEOs of companies that were either in play or trying to defend themselves showed up. The fact that it was nicknamed “The Predators Ball” didn’t turn stop anyone from wanting to be seen there.

Of course “Greed is good” was a mantra of the 1980s. Big money wasn’t driving those deals. The whole reason LBOs became so popular is that corporate raiders didn’t have to put up much of their own cash to get them done. Buyouts included very little equity—that was what made them so profitable.

Yep, UCBerkeley (undergrad), UPenn Wharton (MBA) Michael Millken was indicted on 98 counts of racketeering and securities fraud, plea-bargained it down to 6, was sentenced to ten, but spent only two years in prison, got out, launched a publicity campaign — he was just a “financial innovator for alternative investments,” and is now focuses on philanthropy:  (Biography.com, Jewish Virtual Library**)  Said to be responsible for fueling the takeover booms of the 1980s, made fantastic profits along the way, and proving that, ultimately, crime DOES pay if you play it right.  Or, that “crime is in the eye of the beholders, filtered through public relations with a healthy dose of charitable contributions…”

**… He then launched a public relations campaign to highlight his role as a financial innovator, particularly with regard to popularizing higher-risk alternative investments. He also devoted much time and money to charity over the past three decades. With an estimated net worth of around $2.1 billion as of 2007, he is ranked as the 458th richest person in the world.

Michael Millken, Biography.com (viewed Nov 2017)

So, some famous companies got their start during this time, according to the article — the facilitators, brokers, those that “got the deal done”:

 

(Oct. 20, 2015 in Fortune, “3 reasons…” article, cont’d.

… But at the same time Jacobs and Steinberg and Icahn were making money rattling cages and claiming the moral high ground, the firms that actually did the deals were being formed. Mitt Romney co-founded Bain & Co. in the 1980s. Also founded in the decade were Blackstone (BX, -1.61%), Carlyle Group, and KKR (KKR, -0.68%), which left the decade with the biggest LBO bounty of them all, RJR Nabisco.

Michael Milken invented the modern junk bond, went to prison, and then became one of the most respected people on Wall Street Institutional InvestorWilliam D. Cohan, Institutional Investor May 2, 2017, 5:18 PM 10,810 (shares), as posted on Business Insider.   Well-written, comprehensive.  See paragraphs that start “In 2015 alone….” Or hover cursor over (but do not click on) the article’s title to see the same section (w/o paragraphs).  

One reason so many topics keep coming back to tobacco may be, how large the operations were over time.  From FundingUniverse.com, see “R.J.Reynolds Tobacco Holdings, Inc. History” (through 2000 only; according to the source reference). It’s a fast read, however see at least see the sections “Diversification – 1960s and 70s” (buying food and nonfood companies) and  “Refocusing the Company in the 1980s” and along the way notice how antitrust litigation in 1911 didn’t really slow the company down too much; in fact it helped it get out from underneath a controlling trust (American Tobacco Trust).  The company was even convicted in a 1948 antitrust lawsuit, but managed to rebound and at this time started taking diversification more seriously…

The antitrust theme intersects with content of this post and new page = why I included it just above.  A famous lawyer born right before the Civil War, also a Yale grad, and direct descendant through his grandmother’ line, it turns out, back to the Mayflower, and with powerful families in Boston and through his mother, in Connecticut, specialized in helping wealthy businesses (this one not mentioned, but many in steel, finance, transportation, etc. were) get around antitrust by changing the laws for registration of companies outside their home base, then himself forming a company which specialized in helping them do this (Corporation Trust Company).  Along the lines I continue to complain about on this blog, several of its original directors were also members of government; it was formed as far back as 1892…. This lawyer and his company are still being talked about, and can be seen throughout corporate registration databases (at the state level) today. It just at some point got taken over by a company based in Europe (Wolters Kluwer), which I cover more on the related page….


An image, I believe, from SimpleCharityRegistration.com “About” page (on which I have a new page published 11/11/2017)

The above image drops several names, but doesn’t say WHEN “MRFP” launched the initiative.  That a Guidestar IT executive (Jim Dobrzeniecki) was on the initiative “for years” (from when to when?  since when and for how long?).  Has this project actually been launched yet, or is it still in “development” and “Pilot” stage only? And where is (who owns/controls) “CBT Tech LLC” and who is or are its corporate or personal members, as LLC’s usually have?   If a ‘Culin Tate’ is SCR co-founder, then who’s the other “founder”? (with SCR representing a product, not — so far as we know from this summary — a corporate or even LLC “person.”And why should people who won’t write better simple summaries of themselves be advising, or even running, products supposedly designed for better transparency and efficiency in the nonprofit fields?


Some of the involved organizations, historically, developed major lines of business (revenues) from proprietary control of information databases on nonprofits through which other nonprofits (who would be natural subscribers, and listed on them) may connect with each other, or solicit funds from others on the same databases.  When it comes to, for example, the organization “Guidestar, Inc.,” even a cursory look shows that its primary source of revenues, year after year, has been not contributions, but fees charged for its services — which costs would obviously be passed on to customers one way or another.

@@@(The paragraphs in next quote were also at the top of this post…it’s my voice though):

Post Title: About MRFP, Inc. (NAAG/NASCO’s “Single Portal Initiative” for MultiState Registration and Filing by Charities — except, apparently, for MRFP, Inc, NAAG, and NASCO). Also See my New Page (publ. 11/11/17) on SimpleCharityRegistration.com [This post Publ. 11/18/2017] (case-sensitive shortlink here ends “-7X8”).

Subtitle:  Who’s Regulating the Regulators? Why are they exempt from the rules they exist to enforce?  Wake Up, People!!

Those Acronyms:    “MRFP” = (see post title). “NAAG” = National Association of Attorneys General.  And “NASCO,” it’s said, is National Association of State Charity Officials.

Mutual self-referral is one thing, but where’s NASCO’s registration, corporate, charitable, or with the IRS?  If it’s a project of the NAAG (hints were dropped on both websites), then where’s NAAG’s — charitable, corporate, or IRS filing?  It either is or is not required to file tax returns and register as a charity.  If not, on what basis is the NAAG exempt, and if it is not on some basis exempt from registration, how’s about coughing up some tax returns (it was first formed, say the websites, in 1907)?

And if groups which, such as this one apparently do not file or feel obligated to say why not in the “information age” and in the context of preaching accountability and transparency, really do go back so far as 1907, then what does that say about what’s been growing within the USA for now, approximately 110 years?  And what does this all really say about a population which has enabled this decade after decade by silent assent on what some (including involved employees of such organizations) do know — and others (like myself in a former life) did not know because we (I’m in this category, so “we”) hadn’t yet figured out what we did not know, or how and where to dig-down and discover what lay was beneath — specifically on how leadership within various levels of government interacts with private corporations within the tax-exempt sector?

And then we get all excited and offended when each new “Kids for Cash” (Luzerne County, PA, RICO) scenario surfaces….and provide an audience for those who, aghast, recommend more state- and federal-level transformations to avoid the next one…

From NAAG website, a page “Get to Know National Association of Charity Officials,” describing, sort of, NASCO, minus the links to any supporting documentation of NASCO (or itself) as an actual entity, or even its start date (elsewhere recited as “1979”), although when it merged with NAAG in 1984 is mentioned.

Reading this for coherent content as an adult is like pulling up the virtual chair for a storytelling session not geared for adults…and not much for literature either, unless you count “poetic license…”  Actual connection of the reader to outside evidence of what’s being said here is not provided.

Many organization (private and public) websites could be characterized as “storytelling,” but this is NAAG (which has an EIN# and does not seem to be part of government, but is still without identifiable tax returns, the abbreviated 990-N kind or full-form ones with organized Parts, line numbers, dollar amounts, answers to a variety of questions about organization itself, and required schedules by letter name:  A, B, D,  F, G, I,J, L, M, R among the common ones I keep seeing on other organizations) talking about what may or may not be its own creation, “NASCO.” I deduce from this that possibly both of them (or just NAAG), have either cloned themselves (or NAAG, itself), or had enough intellectual inter,  excuse me, discourse (with each other, or NAAG dynamically with itself, for which I will spare readers the parallel descriptor) such discourse resulting in progeny having occurred either in on-line forums or in annual conferences, face-to-face.  Somehow, there is at least one 21st century offspring , such as MRFP, Inc., for which both (if NASCO has an independent identity) like to, kind of take credit — sort of.

…Although NAAG provided a forum for state Attorneys General with charity oversight responsibilities, that forum did not include Secretary of State offices and other state officials with some of the same charity oversight responsibilities.** NASCO therefore was organized {{by____??}}*** to represent all such charity officials. NAAG’s Charitable Trusts and Solicitations Committee operated independently from NASCO for several years, but in 1984 NASCO informally merged its activities with NAAG’s.

**Why, after potentially decades of providing a forum for Attorneys General, in (from other sources) 1979 someone (NAAG doesn’t take direct responsibility in the sentence) decide add the Secretaries of State “and other state officials” in the forum, is not revealed here.  In fact, having a separate conference for those additional officials served to continue sequestering the NAAG forum, it would seem — as the “Charitable Trusts and Solicitations Committee” operations independence would seem to indicate.

*** “Organized” doesn’t necessarily mean “incorporated,” but use of the acronym implies some sort of entity exists, somewhere, and with a start date, and either incorporators, founders, maybe even by-laws.  That would be closer to a “definition” of who and what IS NASCO, but this description more approaches story-telling at the GED level, with parts of the chronology missing, and other parts, well, only raising more question, in part because of the missing elements, provided in objective, identifiable, FUNCTIONAL terms for further lookups from neutral sources NOT under the direct control of NAAG or NASCO, whoever it is or was…

NASCO members communicate through a list serve, a members-only portion of a NAAG-hosted Web sitewww.Nasconet.org, and through an annual educational conference co-sponsored with NAAG. NASCO has taken a leadership role in promoting uniform state charity registration and filing requirements, amicus briefs, and multistate lawsuits targeting fundraising deception. NASCO also has drafted model state solicitation laws and jurisdictional guidelines for state regulation of charitable solicitation on the Internet.

NASCO also strives to provide a national, unified voice for state regulators to communicate with the IRS, the U.S. Senate Finance Committee, and other constituencies regarding national charity issues. For example, NASCO members have participated in drafting the Uniform Law Commission’s Oversight of Charitable Assets Act, which is nearing approval and seeks to articulate and clarify the common law authority of state Attorneys General to protect charitable assets

Dropdown menu under “About” at NAAG.org. Also note, it doesn’t end “*gov” but “*.org” and appears to be an “org”…

While I’m on that topic, since NAAG actually does have (control) a 501©3 of similar name (shown below), the “NAAG Mission Foundation, Inc.,” then why not at least post ITS financials on the NAAG website?  There’s at least a drop-down menu listing for the Mission Foundation, why not some nice 990s? Or consolidated financial statements for them both?

Perhaps we are just not supposed to think about those things, and by mutual collective assent, not one of those three websites, all of which do exist, refers to such things, either.  Instead, we are treated to story-telling and hypothetical allegations, even under NAAG’s “FAQs page!


And what’s all this got to do with Big Tobacco Litigation of the late 1990s, and since? (Answer: “Lots”  Plenty.  Much!).  For one, look at the NAAG Mission Foundation link, second from the top (next image):

NAAG/About/ dropdown link to this foundation.


I’m announcing a new page again; the 10,000 word page was published 11/11/2017. What’s summarized here is discussed in more detail there. … However this post has the benefit of more understanding that’s been growing day by day, i.e., some hindsight comprehension of where the pieces fit neatly into each other, and into the ability of the tax-exempt sector as an ideal cultivation ground — from the start, and it does seem intentionally — for a safe harbor for monopolies that under the 1893 Sherman anti-trust act, were otherwise under attack.

TheYaleBiographical Dict’y of American Law (Yale Univ. Press 2009 Ed. RogerK Newman) on James B Dill (pp163-164) Google Book “About” pg., Image #1 of 4.

(That’s a tall claim, but generally acknowledged, including among lawyers, to be true.  One reference only here — my new page has more on the origins of The Corporation Trust Company as it came up in the context of SimpleCharityRegistration.com’s “Partnerships.”

Regarding James Brooks Dill (ca. 1854-1910), who founded that company (and, says another source, about thirty prominent trusts) in 1892, attracting such business to New Jersey that it was able to quickly eliminate its Civil War debt and the property tax (note:  this pre-dates the income tax, Federal Reserve System, all that…and appears to have helped facilitate major businesses,  (such as U.S. Steel), sometimes his clients, to continue their multistate concentrations of power) and amending New Jersey’s law to make it easier for out-of-state businesses to incorporate there: The Yale Biographical Dictionary of American Law (Ed. Roger K. Newman, 2009 Yale University Press, 622 pp., pp. 163-164 top (a Google books preview link), :

TheYaleBiographical Dict’y of American Law (Yale Univ. Press 2009 Ed. RogerK Newman) on James B Dill (pp163-164), Image #2 of 4.

TheYaleBiographical Dict’y of American Law (Yale Univ. Press 2009 Ed. RogerK Newman) on James B Dill (pp163-164), Image #3 of 4.

Text betw. Images #3 + 4 reads: “…old-fashioned Ten-Commandment honesty.” (new para). Dill’s 1905 appointment to the New Jersey Court ..”

TheYaleBiographical Dict’y of American Law (Yale Univ. Press 2009 Ed. RogerK Newman) on James B Dill (pp163-164), Image #4 of 4. See the three references

..Not to mention ways to move assets overseas by way of collective investments, and per se (as tax-exempt foundations) reduce contributions which would otherwise occur and contribute to the government receipts, overall, in the United States of America.  Often under private control.

I think perhaps this connection to the role “Corporation Trust (“CT”) company and its founder, and operations since then, played in US and global corporation history may have been the most significant find of the page I wrote, initially just to post a list of where state charitable registration database existed.   (See content of the next three images, found in “Google News” on a general search of his name, to see it in its original (though harder to read) format.  I left a few lines overlap between images to show nothing was skipped…)

For example (from obituary Image #1 of 3, below) his grandmother was the sister of a famous Boston lawyer, Caleb  Cushing (See Bioguide.Congress.gov — 1800-1870, grad. Harvard 1917, then law, the representative, also ambassador, etc.).  Or, the US Britannica article.  Just before Dill was born, 1854, his grandmother’s brother was appointed US Attorney General (1853); also commissioner to China negotiating a significant treaty on “extraterritoriality” (a theme carried over into Dill’s own work on corporation law, it seems), and later Ambassador to Spain.  See that article.

Caleb Cushing from Ency. Britannica (predecessor through his grandmother to James Brooks Dill, founder of the Corporation Trust Company.

His father, a preacher, and pastor of “South Congregational Church” in Chicago, died — in the Civil War — when Dill was just 8; his mother moved to New Haven, Connecticut.  Dill continued his education, age 14 at Oberlin Preparatory Academy, then Oberlin College in 1871 (it had just started ca. 1865) but for only one year, then on to Yale, then taught privately one year studying law under a certain attorney in Philadelphia, then back to New York (teaching privately again, and studying law).  He enter NYU in the senior class, while working also, and graduated as “salutatorian” in 1878. No lack of diligence, perseverance, smarts or focus from an early age, it seems!  He was admitted to the bar, and quickly opened a practice focusing on corporate law… (see image #3 below)….

I see from elsewhere, generally, that Dill’s mother, Catharine Brooks, was the direct descent of Caleb Cushing and from “prominent family” in Connecticut.  Looks like maybe, descendants of Mayflower arrivals, Puritans (link to a genealogy dating to 1901, boasting about the prominence fo the Cushing family, viewable on-line)..

From Google News, James Brooks Dill 1910 Obit in Boston Eve’g Transcript Image #1 of 3

From Google News, James Brooks Dill 1910 Obit in Boston Eve’g Transcript Image #2 of 3

 

 

 

 

 

From Google News, James Brooks Dill 1910 Obit in Boston Eve’g Transcript Image #3 of 3

 

 

Also on this post, just not reflected in the title for lack of space, after the explanatory/introductory material stating my concerns with this situation as representative of “out-of-control” tax-exempt sector used to [re]organize and [inter]nationalize state governments piecemeal by one civil servant category after another (remember, I just also posted on “ICLEI – Local Governments for Sustainability USA, Inc….), I deal with the late (d. 2008) and well-loved actor (and father) Paul Newman’s philanthropic legacy** and, because it is mentioned in connection with soliciting RFI’s for grants to this MRFP, Inc., along with the Charles S. Mott Foundation, perhaps some more ramifications on C.S Mott Foundation’s role in holding 18% of the privataely-controlled “U.S. Sugar Corporation” as typical of the vertical integration, negative environmental consequences, and major philanthropy for clean up of water.  Meanwhile, the Mott Foundation’s home is, ironically, in Flint Michigan, infamous recently for its polluted, unsafe tap water.

That connection (apparently C.S. Mott was key founder of U.S. Sugar Corporation, too, in the early 1900s) is fascinating and seems to demonstrate how corporate monopolies  + big-bucks philanthropy work together to dominate the landscape and maintain as much good public image as possible (which will, of course, help corporate profits too).  Meanwhile, did the U.S. population and consumers really need to get so hooked on sugar that now diabetes is a major concern nationwide?


I think Newman’s Own Foundation (claims, falsely, to have only started in 2005, gross assets well under $1B, but still nearly $¼ billion) and The Charles S. Mott Foundation (started in 1926, gross assets now $2.7B)  a “odd couple” of nonprofits to show up in that context, alongside such other digital and information-age based powerhouses as Guidestar, Inc. (formerly “Philanthropic Research, Inc.”, 1995ff), the “CT Corporation (as controlled now by Wolters Kluwer, based in the Netherlands), Urban Institute “the Urban Institute (<==EIN#520880375 Form 990 for 2015 shows $165M Total Gross Assets), and the assembled state attorneys general and others from secretaries of state offices who regulate charities at the state level.

Upcoming post, based on recent check-in with Urban Institute Form 990 (see above link):

Title:  A Year In the Life (2015, the latest available from this perspective) of a VFTT (Very Famous Think Tank), through its IRS Form 990 Tax Return. (shortlink ends “-7Xz.” Post begun Nov. 13, 2017).

This VFTT entity’s address can be seen in the URL domain name to a one-page, Sept. 2015 description of the Single Portal Initiative and MRFP, Inc. (as “working with” the NAAG/NASCO combo).

Newman’s Own Fndtn, then (terminated 2006, existed since the 1990s) and now (jumpstarted FY2004 with $78.6M in Partnership Interests from Paul Newman himself)

I should also mention again here, that as of FY2009, with the “Tobacco Control Act,” and the FTC (Federal Trade Commission) having authority over tobacco products, we should keep in mind how many, though not all, the well-organized state attorneys general (represented in NAAG or its predecessor names, since 1907), and no doubt their assistants (represented its said in NASCO since 1979, and probably in committees of NAAG earlier) in the late 1990s (while “welfare reform “PRWORA 1996ff was just getting under way with block grants to the states under TANF…) filed a class action against “big tobacco,” and did not win, but did obtain a major settlement.

Is it possible that the monster (billion-dollar) “American Legacy Foundation” now going by “Truth Initiative,” having received its funds, then in 2002 or 2003 granted funds to jumpstart the “National Association of Attorneys General Mission Foundation” (NAAG Mission Foundation financials coming up below)?  That’s what the NAAG (NAAG MF doesn’t have its own) website says regarding its startup…

Next up from this crowd — or probably under way by now — lawsuits against “opioid abuse.”  But, for now, what NASCO (around since 1979, say the various descriptions) seems most proud of, besides this “Single Portal Initiative” is going after the competition, I mean, fake Cancer Charities.

See next two images from “MRFPinc.org” for the references to Newman’s Own and Charles S. Mott Foundations, Click images to enlarge.

Footer + last para. of an MRFP, Inc. announcement on the Single-Portal Initiative.

 

 

 

 

 

 

Continuing from my statement above:

Also on this post, just not reflected in the title for lack of space, after the explanatory/introductory material stating my concerns with this situation … I deal with the late (d. 2008) and well-loved actor (and father) Paul Newman’s philanthropic legacy**

By “deals with” I’m not yet knowledgeable enough to pronounce any evaluation; I mean, “talks about (shows images and discusses details from)” some of the foundations from both the Forms 990PF, the organization website (which is compared and contrasted for honesty in self-characterization) and, not in depth, but FYI, some recent news in MSM from the surviving daughters, themselves long into philanthropy also, concerns with how that legacy is being handled.

The Charles S. Mott Foundation (substantial, long-standing, probably one of the 50 largest in the country, although that depends on what or how one measures) also, I saw from a Form 990PF, just skimming through it, disclosed that it owns 18% of the privately-held U.S. Sugar, based in (The Everglades area of) Florida.  A quick look at the U.S. Sugar’s own website, a Wikipedia (which discussed it selling land to the State of Florida under a 2000ff preservation plan) and a FY2016 Huffington Post article showing how that works out, show me again, that curiosity counts — this is the tip of the iceberg, and typical of philanthropy as a sector in the country. It’s a warehouse of some of the largest private wealth around, and these may (I’d say in Paul Newman’s case) or may not (it sure seems here) be the good guys, or even the nice guys.


***Paul Newman’s philanthropic legacy— which, curiously, involves one foundation whose money was run, under the name “Newman’s Own Foundation,” apparently contributions from Australia, tax-exempt foundation in Connecticut, donations back to Australia and/or New Zealand.  Also interesting to me, that Newman’s Own products, with the first one mentioned in 1982, were being distributed in Australia as early as 1983, and that a successor foundation, started up in 2004 and funded initially with $78.6M from Mr. Newman in the form of “Partnership Interests,” second year of operation, “$40M” (ditto), is being run by two individuals who were also mentioned as co-executors of his estate (of about $600M? per a 2015 Vanity Fair article), one of which is also currently Chairman of “Newman’s Own.”  The second foundation caught my attention immediately because of its controlled entities and the pass-through income.

So this post exists to introduce a new page and its subject matter, to put what I have so far on the Newman Foundation (and there ideally will be more on the Charles S. Mott/U.S. Sugar situation, possibly post-publication) “out there” for my about 3,000 followers and anyone else who might stray across this site.

EXPLANATORY / INTRODUCTION, incl. “The Problem”:

I discovered perhaps a week ago, a list of state charitable registration sites I thought would be helpful for this blog.  In the process, as usual, I paid attention to the window frame (URL domain name, looking for company or corporation names attached to the service being advertised.

I was immediately struck by how scarce, unfinished, and rather inarticulate the website was on its partners and its owners — while, naturally, encouraging consumption of its services.

On looking a little closer, I saw why, in their shoes, I might not have wanted to be upfront about the international nature of at least one of the partners, and the national-association-based promotion of the initiative.  In general, this whole subject relates to the digitization of important data involving not-for-profit corporations, and the tax-exempt sector regulators at the State levels (typically, but not only, State Attorneys General and their assistants — but because corporate registrations too get involved, also, officials at the Secretary of State offices).

It should be clear, quickly, that the Attorney General is the top of ONE branch of government, and the Secretary of State, ANOTHER branch, but the association tying them together — “NASCO,” named in the title and which (at this point I don’t yet know) may or may not exist not as an entity, but as a project of the other association named in the title “NAAG.”  So the “unidentified as corporation or 990-filer” status of NASCO, so far as I can tell (after less than a week’s exploration) is a red flag, as are many other aspects, some of them stated on a related Page I just published on this topic.


Unlike in some situations (such as with the domestic violence, HHS grantee “Domestic Abuse Intervention Programs or “DAIP” for short) where I could tell that its project “Battered Women’s Justice Project” (with website BWJP.org) was NOT an incorporated entity, but a DAIP project by simply reading DAIP Forms 990 which said so (until BWJP spun off from DAIP and incorporated, not until the second decade of this century, as I recall 2011 or 2013), this time I could not look up an NAAG IRS Form 990 and see whether or not NASCO was its project — because no NAAG forms 990, so far, are showing up.  And it’s said to have existed since 1907 (!!)  Its supporting foundation, however, dates only to about a century later, in 2002.  That supporting foundation, however, was where I did locate an EIN# for the “NAAG.”  Here are some explanatory (if you read the captions also) images showing my concern about the “MIA” status of an investment-guiding entity whose members are restricted to State Attorneys General.  Not to mention, NAAG also seems to be acting, at least in some capacities, as a sort of Fiscal Agent for “NASCO.”  The first image is from a NAAG website describing NASCO; the others do not refer to NASCO, but are from Form 990 tax returns of an NAAG supporting foundation started somewhere around 2002, with tobacco settlement funds — which may explain its large size despite minor if any  (I DNR at the moment) “Contributions” over time….

A Transparency Problem from those in charge of regulating transparency and accountability of OTHERS in the public interest: The NAAG website (which omits any financials, but talks about them somewhat evasively in places) describing “NASCO” which financials I can’t find on the NASCOnet.org website either, or anywhere else…

Images from “990finder.foundationcenter.org” search results (also posted as tables with active links to the underlying tax returns in my related “page” published 11/11/2017 on this topic):

Form 990 search results by EIN# reveals at least the supporting foundation to “NAAG” with an attached EIN# (first found by name-search).

NAAG MISSION FOUNDATION acknowledging its “single (and controlling) member” is NAAG..

NAAG MISSION FOUNDATION (FY2013? it’s on several years’ of returns) is where I found an EIN# for the NAAG itself: 521322260. This excerpt seems to be from the “Reason for (tax-exempt) status” page — it qualifies as a supporting organization to the NAAG, which is identified here.  That’s the basis for NAAG Mission Foundation’s being able to commandeer millions of dollars in a tax-exempt corporation.  Note: name searches (as opposed to EIN# searches) for NAAG financials produced nothing, so far.

NAAG Mission Foundation, which by its own admission is controlled by the Executive Committee of NAAG “proper” (for lack of a better term), which financials are “MIA,” as we can see, is investing some of its about $79M assets (that year or nearby year) in Central America and the Caribbean.

It’s very fine print, but does give an actual EIN# for NAAG ( 521322260). This as you can see is a FY2013 NAAG Mission Foundation Form 990, Sched R pts. I (empty) and II, tax-exempt (click image to enlarge)…

Just one of several places I tried to dredge up a tax return — or anything! — for the NAAG EIN# as proffered to the public on NAAG Mission Foundation Form 990s over time. This pattern mimics, I believe, the relationship between the NGA (National Governors’ Association) and its “NGA Center for Best Practices” with some differences — including that several other places continue to characterize this NAAG EIN#521322260 as belonging to a “PC” (public charity — the kind that has to file!).

On 11/11/2017, after some days of rapt attention to this new area of learning about how many different ways (and how many red flags along the ways) government employees of high rank and authority over and responsibility to regulate major parts of the private sector can and so often do form private-sector corporations, boasting among each other and on the private-sector corporate websites (which many of the public may never stumble across, ever…) about the public benefits for the project — and doing this all while withholding/concealing identifiable registration of the same private-sector (tax-exempt of course), or failing-to-file, and/or failing-to-file-IRS Forms 990 even when they may have registered,* and in general thus distracting the public from one of the most critical things that public deserves to know,** I published a new page containing a helpful list, alpha by state, of where charities have to register…unless they don’t because for some reason they’re exempt.

Page Title: State-by-State Charity Lookup Links (from SimpleCharityRegistration.com’s March 2017 WordPress post)   Started Nov. 8, 2017, Published Nov. 11; intended for my “Vital Links” sidebar menu. Case-sensitive, generated short-link ends “-7Vm”

Recommended — read that Page before this Post for better statement of context.

*For example, in the State of Connecticut charities MUST register — UNLESS:

CT DCP Charity Registration Rules. Notice description as “all organizations that solicit money for charitable purposes.” Not all nonprofits seem to need to solicit money exist, for example, if they have ample assets enough to sustain them at startup.

CT DCP Charity Registration Rules: List of Exemptions from “financial requirements and filing fees”

I was on that website in the process of looking for the Form 990 of the initially hard-to-find MRFP, Inc., for the basic reason that none were found, until a search of the IRS Exempt Organizations Select Check turned up an EIN#, and that EIN# showed an address in Connecticut…So, the MRFP, Inc. did register in Connecticut (but not until 2016), and then characterized itself as “exempt,” as did the Delaware Filing for the same corporation name in FY2013. (Which I posted on the related page and so won’t, here.) Question:  If it didn’t register in CT until 2016, but registered and filed with the IRS in 2014, as located in “Washington, D.C.,” where was it between 2013 and 2016?

**We deserve free access to, and should not have to hunt so hard for, the dot-to-dot, to/from financial records of transactions with both the From and the To described in definable terms and as connected to legally authorized functions.

  • entity type, and when formed, by whom (incorporators, if it’s incorporated, founders, if not) and where (in which legal domicile — that means state or territory or “D.C.”)

the connections between government receipts** and government distributions to paid officials for whose salaries AND pensions the public is allegedly taxed for– including ALL moon-lighting, restructuring, cutting-edge (?) activities in association with already powerful associations — and the IRS  [“Government” as used here refers to “government entities,” with an emphasis on federal and state, but it’s well known that these are not the only kinds, including joint powers authorities, regional entities, multi-state entities (like “WestEd” I blogged last year, 2016), public school districts (which are specialized government entities per the U.S. Census Bureau) and let’s not forget the secondary universities also, where they function as entities and not state-controlled “corporations.” ].

The situation almost makes me want to go out and get qualified as a CPA just to get some plain answers….

We deserve to know because of the major role perpetual, ongoing contributions to government receipts occurring for most people, throughout their adult lives, from our collective salaries, paychecks or personal income (with or without advance withholdings), or anything else that could be an is taxed to support the many infrastructures in which we live.  Even those on welfare, as I’ve learned over the past decade (plus some), are contributing unawares, probably, of how many other jobs their poverty supports, and which Psy.D., Ph.D., J.D., and yes, M.D., resumes it fills out as their lives become subject matter of social science R&D on “evidence-based practices” to prevent the bad (such as violence, poverty, crime, human trafficking, cancer, etc.) and protect the vulnerable.

 

NEWMAN’s OWN FOUNDATION/s — both of them:


The Newman’s Own Foundation situation (also mentioned on the MRFP one-page announcement) involves two different entities, one terminating itself in 2006, and another one in Westport Connecticut, which received the few remaining assets.  The prior one had, it said, 85% foreign (Australia) funding.  Not to clutter up this page too much, but here are those Form 990s tables.  (Some or all of this section may be removed to a post in the future.  However, when only two well-known foundations were mentioned on the MRFP, Inc. page, above, I wanted to look into the other one also.  From the first look, questions arose, some of which are partially validated after I took a closer look, in that Newman’s own family members are having issues with the foundation, although not the ones I mention below.Question: why would Newman’s Own Foundation be so interested in this project?  Why did it run a foundation IN Australia, funded FROM Australia and granting TO Australia up until 2006, but from entity address Connecticut, (Westport, CT) then terminate this and move minor remaining assets to a new one with a new EIN#, also based in Connecticut?

Yes I am aware he died in 2008.  May discuss later on a post featuring this new page:  The current foundation’s wealth comes directly from Paul Newman (originally, first return FY2004) in the form of “partnership interests” and, strangely, the Foundation controls (holds 99% and 100%, respectively) several partnerships and the C-Corp Newman’s Own, Inc.  Income is flowing through from them.

FY2013, EIN#06-0616588 excerpts showing controlled entities, assets, and major pass-through income.

FY2013, EIN#06-0616588 excerpts showing controlled entities, assets, and major pass-through income.

FY2013, EIN#06-0616588 excerpts showing controlled entities, assets, and major pass-through income.

FY2013, EIN#06-0616588 excerpts showing controlled entities, assets, and major pass-through income.

The Australian (so to speak – earlier) Newman’s Own Foundation board of directors were Paul Newman, Joanne Woodward and Jamie Girard.  The successor, or at least new one by the same name also in Connecticut, in 2004 had the same three + two more men, Robert Forrester of CT and Brian Murphy (at least in earliest return) of Santa Monica, California.  In an Amendment to the By-laws ca. 2010, the latter two men became “Primary Members” with the authority to choose or expel other members, etc., until they were dead or incapacitated…  (I see from their website that Mr. Forrester also runs Newman’s Own).

(I also just learned from this Vanity Fair article, 2015, that Forrester and Murphy were co-executors of Paul Newman’s will, and that the family (surviving daughters) are having some serious disagreements with how both the company and the foundation are being handled.


Total results: 6Search Again.  Newman’s Own Fndtn, New# 06-1606588, Old# 06-1247230.

ORGANIZATION NAME ST YR FORM PP TOTAL ASSETS EIN
Newman’s Own Foundation CT 2015 990PF 103 $231,096,299.00 06-1606588
Newman’s Own Foundation CT 2014 990PF 99 $228,750,023.00 06-1606588
Newman’s Own Foundation CT 2013 990PF 104 $222,822,875.00 06-1606588
Newman’s Own Foundation, Inc. CT 2006 990PF 21 $0.00 06-1247230
Newman’s Own Foundation, Inc. CT 2005 990PF 44 $153,551.00 06-1247230
Newman’s Own Foundation, Inc. CT 2004 990PF 32 $434,959.00 06-1247230

Thinking aloud here…. From “Newman’s Own Foundation Timeline.” First product, 1982, and almost immediately (1983) marketed in Australia. A foundation funded FROM Australia and with grants TO Australia and NZ is found (not exactly mentioned on this website, it seems) as a United States 501©3, filing Form 990PFs back to at least the mid-1990s, and seemingly 100% (tax returns said 85%) was funding FROM Australia, meaning someone else is running money THROUGH it to (see those tax returns) multiple charities, small amounts, with hand-scrawled descriptions of what each did. Why run money from Australia to the USA and right back to Australia? (amounts MUCH less than the later foundation formed in 2004)….

Interesting listing of which (Commonwealth + the USA) countries…

 

ONE foundation is referenced, but as I just showed, at least two versions under the exact, same name have existed, including one formed well before 2005 as described in the timeline here. Giving it all away, naturally, reduces any corporate taxes paid by underlying for-profit entities, and is great “PR” for products. The newer foundation, so far, is, obviously, not “giving it all away.” (See $221M assets held), and average distribution % much lower than the earlier one..

Claiming the “Newman’s Own Foundation” started in 2005. Well, see the former one dating back to at least 1996 or 1997.. So was this truth-in-advertising?


End, “Newman’s Own Foundation” section; back to the NAAG/NASCO topic:

FOOTNOTE ROBIN HOOD FOUNDATION: TRUST THE RICH TO RE-ALLOCATE FUNDS FROM THEMSELVES TO THE POOR, WHILE NOT POSTING THEIR OWN FINANCIALS:

Robin Hood Fndtn home page. NO links on dropdown menus lead to any financial statements, let alone tax returns…

Total results: 3Search Again

ORGANIZATION NAME STATE YEAR FORM PAGES TOTAL ASSETS EIN
Robin Hood Foundation NY 2015 990  132 $462,935,695.00 13-3441066
Robin Hood Foundation NY 2014 990  295 $446,826,179.00 13-3441066
Robin Hood Foundation NY 2013 990  528 $447,689,231.00 13-3441066
…..

Written by Let's Get Honest

November 18, 2017 at 8:53 pm

One Response

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  1. daveyone1

    November 19, 2017 at 1:08 pm


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martinplaut

Journalist specialising in the Horn of Africa and Southern Africa

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