TC4 Trust

Background

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.”¹

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.²

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.

Funding

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.³

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
Funded Directly	$2,500,000	$6,616,000		$9,116,000
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
Freedom Club		$75,000		$75,000
Themis Trust	$2,500,000			$2,500,000
YEM TRUST, LLC		$500,000		$500,000
Grand Total	$6,339,000	$30,439,493	$28,380,887	$65,159,380

*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

Key People

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 ⁵

Actions

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 2010.⁶

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.⁷

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.⁸

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.