45Committee, Inc., a nonprofit organization that spent more than $21 million boosting President Donald Trump during the final month of the 2016 election, was financed by more than $46 million raised from a small group of megadonors, including 11 who wrote checks of $1 million or more, according to a new tax return obtained by CREW. The average contribution received by the organization was $2.3 million during the the time period covered by the filing, April 1, 2016 to March 31, 2017.

The bulk of 45Committee’s funding came from four separate $7.5 million contributions, totalling $30 million and accounting for 65 percent of the group’s revenue. As a a social welfare organization under section 501(c)(4) of the tax code, 45Committee is not required to disclose its donors, but The New York Times has reported that the group was “heavily funded” by casino owner Sheldon Adelson.

Todd Ricketts, a co-owner of the Chicago Cubs who President Trump later nominated to be Deputy Secretary of Commerce and recently was named to replace Steve Wynn as the Republican National Committee finance chair, spearheaded 45Committee’s fundraising. According to Politico, Ricketts used the fact that 45Committee could accept giant checks while keeping donor names secret to pitch donors uncomfortable being associated with Trump.

What did all those seven-figure checks pay for? 45Committee reported spending $45.5 million overall and acknowledged spending $21.6 million on political activity, meaning the group admitted political activity accounted for 47.5 percent of the organization’s total spending during its 2016 fiscal year.

Though a tax-exempt nonprofit like 45Committee is allowed to spend money on politics, influencing elections cannot be its primary activity, which is commonly interpreted as dedicating more than 50 percent of its spending to political activity. 45Committee’s ability to keep its contributors secret is also dependent on not being considered by the FEC to be a political committee with the major purpose of electing or opposing candidates for federal office. The group had previously reported to the Federal Election Commission (FEC) spending more than $21.3 million on independent expenditures supporting now President Trump and opposing former Secretary of State Hillary Clinton.

45Committee mostly claimed to have offset its political spending with advertising that did not expressly advocate for the election or defeat of a candidate, reporting spending $18.9 million on “issue ads and media.” This spending appears to include as an ad about Iran sanctions that criticized then Rep. Patrick Murphy (D-FL), a Senate candidate at the time, right before Election Day 2016. 45Committee reported the ad to the FEC as an electioneering communication and said it spent $671,320 to produce and place it. The “issue ads” spending also appears to include several other ads that ran in the months before the 2016 election, like one featuring former President Bill Clinton criticizing the Affordable Care Act and calling on viewers to contact President Obama about it, and another encouraging the impeachment of then IRS Commissioner John Koskinen. The $18.9 million figure also appears to include close to $4 million the group spent in early 2017 to promote President Trump’s cabinet nominees.

45Committee further offset its political spending by providing more than $3.5 million in grants to other nonprofit organizations, including several that spent money to influence the 2016 election. The largest grant was given to Secure America Now, a conservative nonprofit that received $2 million. 45Committee’s grant was enough to easily cover the more than $1 million Secure America Now reported spending on independent expenditures in 2016, though it is impossible to know without more information if the grant directly funded the political expenditures.

45Committee also contributed to three other nonprofits that reported making independent expenditures during the 2016 election, giving $350,000 to the U.S. Chamber of Commerce, $275,000 to the Susan B. Anthony List, and $70,000 to the NRA Institute for Legislative Action. The group also made six-figure contributions to the John Hay Initiative, the Faith and Freedom Coalition, the Judicial Crisis Network, American Encore, and the Shining City Community.   

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