TC4 trust was a nonprofit Koch network organization, described as a “shadow money mailbox.” According to a 2013 OpenSecrets report, TC4 and another group, the Center to Protect Patient Rights (CPPR), primarily operated “to further cover the tracks of tax-exempt groups that have provided major sums to help Republican causes in the 2010 and 2012 elections.”1Robert Maguire and Viveca Novak. “Exclusive: Largest Dark Money Donor Groups Share Funds, Hide Links,” OpenSecrets.org. September 10, 2013. Archived July 31, 2019. Archive.fo URL: https://archive.fo/GoRG8
TC4 was incorporated as a 501(c)(4) non-profit organization, and is no longer in operation. Its termination was reported on its 2011/2012 IRS Form 990 filings, which were signed May 14, 2013 by trustee Michael Hartz.2TC4 Trust’s 2011-2012 990 tax form. Retrieved from DocumentCloud.
Stance on Climate Change
TC4 Trust did not have an apparent stance on climate change. However, it funded groups that sided with inaction on climate, such as the 60 Plus Association.
As reported by OpenSecrets, much of the money given by Koch-controlled groups – including the Center to Protect Patient Rights (now American Encore) and the TC4 Trust – were funneled through obscure limited liability corporations that the IRS refers to as “disregarded entities” for tax reporting purposes.3Robert Maguire and Viveca Novak. “Koch Group’s IRS Report Unlocks A Few Mysteries,” OpenSecrets, September 18, 2013. Archived July 30, 2019. Archive.fo URL: https://archive.fo/z1Sao
A disregarded entity is a business entity, such as a limited liability corporation (LLC), that is not taxed separately from its owner by the federal Internal Revenue Service.
The following is based on information retrieved from the TC4 Trust’s IRS Form 990 tax filings. Note that this list includes a number of LLCs that obscure the actual destinations of funds. The decoded recipient names are listed below, along with the related disregarded entity names when included.
See the attached spreadsheet for additional information on TC4 Trust funding by year (.xlsx).
|Recipient Name||2010||2011||2012||Grand Total||Disregarded Entity Name(s)|
|Funded via Disregarded Entities||$3,839,000||$23,823,493||$28,380,887||$56,043,380|
|Americans for Prosperity||$891,800||$500,000||$1,391,800||PR-DIST, LLC|
|Center for Shared Services Trust||$1,262,387||$1,262,387||RION, LLC|
|Center to Protect Patient Rights||$3,839,000||$9,801,000||$14,314,000||$27,954,000||CORNER TABLE, LLC (2012); Eleventh Edition, LLC (2011); American Commitment, LLC (2011);|
Name Unclear* (Meridian Edition LLC) (2009)
|Concerned Veterans for America||$1,968,500||$1,968,500||TOHE, LLC|
|Evangchr4 Trust||$725,000||$725,000||ORRA, LLC|
|Generation Opportunity||$1,500,000||$2,130,000||$3,630,000||TRGN, LLC|
|Libre Initiative Trust||$693,000||$693,000||TDNA, LLC|
|Public Engagement Group Trust||$1,993,000||$1,993,000||SLAH, LLC|
|Public Notice||$7,330,693||$1,670,000||$9,000,693||POFN, LLC|
|Themis Trust||$4,300,000||$3,125,000||$7,425,000||STN, LLC|
|60 Plus Association||$4,061,000||$4,061,000|
|Center for Shared Services||$500,000||$500,000|
|Concerned Women for America||$1,335,000||$1,335,000|
|Council for Citizens Against Government Waste||$145,000||$145,000|
|YEM TRUST, LLC||$500,000||$500,000|
*Note that while the name is unreadable in the original 2010 IRS Form 990 filing, the EIN matches that of Meridian Edition, LLC, a disregarded entity of the Center to Protect Patient Rights/American Encore. According to CPPR‘s IRS Form 990s, Meridian Edition formerly went by the name of American Commitment, LLC.
IRS Form 990 Filings
Michael O. Hartz was listed as a trustee on all available TC4 Trust IRS Form 990 filings. His was the only name listed on the group’s 2010 and 2011/2012 forms. A Michael Hartz is listed as a former director of the Knowledge and Progress Fund, one of several Koch Family Foundations.
In 2009, Gretchen Hamel was listed as “program leader” on TC4 Trust IRS Form 990 filings. According to the filing Hamel worked 45 hours per week and received $50,000 in compensation that year, plus $1,950 in “other compensation.” Hamel is a PR specialist and former Bush administration appointee. In 2010 She launched another Koch-tied group, Public Notice, and was founder and partner of the PR firm Endeavour Global Strategies. According to a profile on the company’s website, “prior to founding Endeavour Global Strategies, Hamel was Deputy Assistant U.S. Trade Representative (USTR) for Public and Media Affairs, where she served as the spokeswoman on trade for the Bush Administration.”4“Former Bush Admin. Spox Launches Non-Profit To Combat ‘Over-Spending’,” Talkingpointsmemo, March 3, 2010. Archived July 31, 2019. Archive.fo URL: https://archive.fo/mmwg2 5“GRETCHEN HAMEL,” Endeavour Global Strategies. Archived June 22, 2011. Archive.fo URL: https://archive.fo/VZfVl
TC4 Trust’s primary activity was acting as a funding conduit for other Koch-controlled organizations. OpenSecrets reported that over the course of its existence, TC4 Trust made over $64 million in grants. One of its largest grantees was Themis Trust, a conservative voter database project started by David and Charles Koch in 2010.6Robert Maguire and Viveca Novak. “Koch Group’s IRS Report Unlocks A Few Mysteries,” OpenSecrets, September 18, 2013. Archived July 30, 2019. Archive.fo URL: https://archive.fo/z1Sao
Themis Trust also used its own set of disregarded entities to pull in grants, with money coming through groups such as STN, LLC, and DAS MGR. Grants from TC4 Trust to Themis Trust were made through its variety of funding vehicles, and totaled $9.9 million.7Robert Maguire and Viveca Novak. “Koch Group’s IRS Report Unlocks A Few Mysteries,” OpenSecrets, September 18, 2013. Archived July 30, 2019. Archive.fo URL: https://archive.fo/z1Sao
TC4 Trust shunted $725,000 to ORRA, LLC, a disregarded entity of Evangchr4 Trust. Evangchr4 was formally a “related organization” of Themis Trust. Evangchr4 gave out $1.2 million in grants, including $1.2 million in grants to a group titled CitizenLink, the 501(c)(4) arm of social conservative group Focus on the Family. CitizenLink also spent at least $2.6 million in independent expenditures related to Republican presidential nominee Mitt Romney, according to its filings at the Federal Election Commission.8Robert Maguire and Viveca Novak. “Koch Group’s IRS Report Unlocks A Few Mysteries,” OpenSecrets, September 18, 2013. Archived July 30, 2019. Archive.fo URL: https://archive.fo/z1Sao
- RGSN, LLC – TC4 Trust listed one disregarded entity on its 2011/2012 IRS Form 990 filings: RGSN, LLC, located at 5810 Kingstowne Center Drive, Alexandria VA, 22315, which was also TC4 Trust’s address. RGSN has the EIN 27-3653137.
Contact & Address
Via the TC4 Trust’s 2011–2012 IRS Form 990 filing:
TC4 Trust had no activity on social media channels.
- “TC4 Trust,” SourceWatch
- 1Robert Maguire and Viveca Novak. “Exclusive: Largest Dark Money Donor Groups Share Funds, Hide Links,” OpenSecrets.org. September 10, 2013. Archived July 31, 2019. Archive.fo URL: https://archive.fo/GoRG8
- 2TC4 Trust’s 2011-2012 990 tax form. Retrieved from DocumentCloud.
- 4“Former Bush Admin. Spox Launches Non-Profit To Combat ‘Over-Spending’,” Talkingpointsmemo, March 3, 2010. Archived July 31, 2019. Archive.fo URL: https://archive.fo/mmwg2