According to a report today from Real Clear Politics, Trump used his personal foundation, which he has not donated to since 2008 and is “funded by outside donors,” to make donations to prominent conservative groups, including Religious Right organizations, as far back as 2011.
Trump’s foundation contributed to social conservative groups in key GOP primary states such as South Carolina’s Palmetto Family Council and Iowa’s The Family Leader. Other beneficiaries included the Billy Graham Evangelistic Association, led by Franklin Graham; the Citizens United Foundation, run by future Trump campaign official David Bossie; and the American Conservative Union Foundation, which hosts the annual Conservative Political Action Conference (CPAC).
“Such contributions, if they were made solely for Trump’s benefit, could violate federal self-dealing laws for private foundations,” RCP’s Rebecca Berg notes.
From 2011 through 2014, Trump harnessed his eponymous foundation to send at least $286,000 to influential conservative or policy groups, a RealClearPolitics review of the foundation’s tax filings found. In many cases, this flow of money corresponded to prime speaking slots or endorsements that aided Trump as he sought to recast himself as a plausible Republican candidate for president.
Although sources familiar with the thinking behind the donations cautioned that Trump did not explicitly ask for favors in return for the money, they said the contributions were part of a deliberate effort by Trump to ingratiate himself with influential conservatives and brighten his political prospects.
If the Trump foundation sent its money to The Family Leader and not its affiliated nonprofit, it did not properly note it in the filing and might have failed to earmark the money for charitable purposes, a violation of IRS rules. If the money was sent to the Family Leader Foundation, it was not recorded as such.
“If what he talked about was promoting his candidacy or fundraising for his campaign, it is not only self-dealing but potentially involves the foundation in making a grant to support political activity,” said [Rosemary] Fei. “That’s prohibited.”