Module 3: The Anonymous Donor
How Donor-Advised Funds legally erase the donor’s name from the donation — and why both sides of the aisle use the same machine
By the PMC Investigations Desk · Project Milk Carton · Module 3 of “The Game You Were Never Taught” · Financial Move 1 of 8
The move
This is the first of eight financial moves we will map in this series. Each move is a discrete, repeatable, legal technique that shows up across American politics, advocacy, and foreign influence — on both sides of the aisle, among both domestic and foreign-aligned operators. Each module follows the same structure: explain the move, show a red-coded case study, show a blue-coded case study, and hand you the citizen action card.
The first move is DAF Stacking — the use of Donor-Advised Funds to legally sever a donor’s identity from their donation.
How it works — in plain English
A Donor-Advised Fund is not an organization. It is a giving account held at a sponsoring public charity. The three largest DAF sponsors in the United States are Fidelity Charitable, Schwab Charitable (recently rebranded as DAFgiving360), and the National Philanthropic Trust.
Here is the sequence:
Step 1. A donor deposits money into a DAF account at a sponsoring charity. The deposit can be cash, appreciated stock, real estate, cryptocurrency, or other assets.
Step 2. The donor receives an immediate tax deduction for the full fair market value of the deposit — in the year the deposit is made, regardless of when the money is actually distributed to a recipient.
Step 3. The money sits in the DAF account. It can be invested. It can grow. There is no legal requirement for the money to be distributed on any timeline. It can sit for years. Decades. Forever. (This is one of the most significant structural criticisms of DAFs — they receive the tax benefit of a charitable donation without any obligation to actually distribute the money to a working charity.)
Step 4. When the donor is ready, they “advise” the sponsoring charity to make a grant to a specific 501(c)(3) recipient. The sponsoring charity reviews the recommendation and, in virtually all cases, approves it.
Step 5. The grant arrives at the recipient organization. On the recipient’s Form 990, the grant is reported as coming from the sponsoring charity — Fidelity Charitable, Schwab Charitable, National Philanthropic Trust — not from the individual donor.
Step 6. The donor’s name does not appear on any public filing at the recipient. It does not appear on the recipient’s 990. It does not appear on the DAF sponsor’s 990 (which aggregates all grants without attributing them to individual account holders). The only entity that knows the donor’s identity is the DAF sponsor — and the DAF sponsor is not required to disclose it to the public, to the recipient, or to any regulator other than the IRS.
The donor vanishes.
The scale
A 47-fold increase in assets in 24 years. Every dollar of that growth is a dollar that moved from traceable giving to anonymous giving.
The three largest DAF sponsors together distributed more than $27.5 billion in a single year: - Fidelity Charitable: $11.8 billion - Schwab Charitable / DAFgiving360: $4.7 billion - National Philanthropic Trust: $11 billion
To put that in perspective: the total annual giving by the top 25 private foundations in America — Gates, Ford, Walton, Bloomberg, all of them combined — is roughly $15 billion. The top three DAF sponsors alone distribute nearly twice that. And unlike private foundations, DAFs disclose zero donor information to the public.
Why this is the first move
We are starting here because the DAF is the entry point of the entity stack. Before money flows through (c)(4)s, before it funds Super PAC ads, before it crosses borders through foreign-principal pass-throughs — the donor’s identity is erased. The DAF is how the erasure happens.
Every subsequent move in this series operates more effectively when the original donor is anonymous. Entity laddering is more powerful when the funder is invisible. Foreign-principal pass-throughs are harder to detect when the domestic funding source is anonymized. “Educational” classification abuse is harder to challenge when nobody knows who is paying for the “education.”
The DAF does not cause the abuse. The DAF enables the opacity that makes the abuse undetectable.
There are legitimate uses
We are not arguing that DAFs should not exist. We are arguing that citizens should understand what they are and how they work.
There are genuine reasons a donor might want anonymity: - A domestic violence shelter supporter who fears the abuser - A controversial-cause donor who fears harassment - A family that gives generously and does not want to be deluged by solicitations - A whistleblower supporter who needs operational cover
The charitable deduction for DAF deposits incentivizes giving. The anonymity feature protects donors from retaliation. These are real benefits with real value.
The problem is not that the mechanism exists. The problem is that it scales. The same anonymization that protects a $500 shelter donation from an abuse survivor also protects a $50 million political-infrastructure deposit from a megadonor who wants to reshape American policy without anyone knowing their name. The rules do not distinguish between the two. The mechanism is identical at any dollar amount.
Case Study A (red-coded): The Elev8hope $60,000 Mystery
Elev8hope Inc. is a 501(c)(3) registered in Florida. EIN: 90-0806545. Principal address: 3700 SE Salerno Road, Stuart, FL 34997. Its stated mission involves community support and anti-trafficking work.
In its FY2024 filing, Elev8hope reported total revenue of $892,895, of which 93.5% came from contributions. Its CEO, Rina Shpiruk, received compensation of $184,691 — a 45.8% year-over-year increase. The organization has been administratively dissolved by the state of Florida three times (2013, 2019, 2021) and reinstated each time.
Among its identified funding sources, PMC’s financial forensics traced a $60,000 contribution from DAFgiving360 — the Schwab Charitable rebrand.
Who gave the $60,000? We do not know. The DAF rules are why.
The recipient’s 990 shows “DAFgiving360” as the grantor. The DAFgiving360 990 aggregates all of its distributions without attributing individual grants to individual account holders. There is no public filing — federal, state, or local — that connects an individual donor to this $60,000 grant.
PMC’s investigation identified Elev8hope as part of a broader network under examination in BROKEN MIRROR. Specific individuals associated with the network attended Elev8hope fundraising events (a Casino Night event raised approximately $200,000; a Lip Sync Battle event raised $300,350). But attendance at a fundraiser is not the same as being the anonymous DAF donor. The trail ends at DAFgiving360 because the IRS rules say it ends there.
What this illustrates: A grant of $60,000 — significant for a small (c)(3) with under $900,000 in annual revenue — arrived through a mechanism that makes it impossible for the public, the press, or any external investigator to determine who sent it. The donor’s identity is not hidden by fraud. It is hidden by design.
Case Study B (blue-coded): The Arabella Advisors DAF Pipeline
On the other side of the aisle, the DAF mechanism operates at vastly larger scale through a network managed by Arabella Advisors, a for-profit consulting firm based in Washington, D.C.
Arabella manages four major 501(c)(3) nonprofits — the Sixteen Thirty Fund, the New Venture Fund, the Hopewell Fund, and the Windward Fund — plus a 501(c)(4) called the Sixteen Thirty Fund (a separate entity from the (c)(3) of the same name, which has since been renamed the Advocacy Fund). Together, these entities manage more than $1.5 billion per year in revenue.
These entities function as fiscal sponsors — they host hundreds of “projects” that operate under Arabella’s umbrella without incorporating independently. Each project receives funding through the Arabella-managed entity. Donors contribute to the Arabella entity — often through DAFs — and the Arabella entity distributes the money to its projects.
The DAF layer is critical. A significant portion of funding flowing into the Arabella network arrives via DAFs — Fidelity Charitable, Schwab Charitable, the National Philanthropic Trust, community foundations, and others. The Arabella entity’s 990 shows the DAF sponsor as the grantor. The DAF sponsor’s records show an anonymous account holder as the advisor. The original donor is invisible behind two layers of legal anonymity: the DAF layer and the fiscal-sponsorship layer.
The scale is enormous. ProPublica, the Capital Research Center, and other watchdog organizations have documented that the Arabella network has channeled more than $3.5 billion in total since 2006 through its managed entities. The D.C. Attorney General opened an investigation into self-dealing allegations — specifically, $230 million in consulting fees paid to Arabella Advisors by its own managed nonprofits.
What this illustrates: The identical DAF mechanism that hid a $60,000 donor from a small Florida (c)(3) also hides the identity of donors funding a $1.5 billion-per-year political-advocacy infrastructure on the opposite side of the aisle. Same sponsoring organizations. Same IRS rules. Same anonymization. Different politics. Different scale. Same move.
The symmetry is the point
If you are a reader whose politics are on the right, Case Study A may have felt more concerning to you. If your politics are on the left, Case Study B may have felt more concerning.
That reaction is itself evidence of how the game works.
The mechanism is identical. The rules are the same. The DAF sponsors are the same companies (Fidelity, Schwab, NPT serve donors across the political spectrum). The anonymization is equally complete on both sides. The only difference is which direction the money flows after the donor’s name disappears.
We are not asking you to be equally outraged at both case studies. We are asking you to notice that the same move produced both outcomes — and that the move itself is the thing worth understanding.
The DonorsTrust question
There is a specialized DAF that deserves separate mention because it explicitly markets itself as a conservative donor vehicle: DonorsTrust (and its sister entity, Donors Capital Fund).
DonorsTrust operates as a DAF sponsor specifically for donors who want to ensure their contributions fund organizations aligned with “liberty” and limited-government principles. It is the conservative movement’s purpose-built anonymization engine.
PMC’s investigation in IRON CURTAIN (OP-2026-0011) traced $4.4 million flowing from DonorsTrust to the America First Policy Institute (AFPI, EIN 85-4202763) in 2024 alone — a 27-fold increase over prior-year DonorsTrust grants to AFPI. AFPI’s total revenue is approximately $51 million.
Separately, the National Christian Charitable Foundation (NCCF) shows a $4.6 million DAF in its filings whose redistribution recipients remain unconfirmed — an intelligence gap PMC has flagged as high priority.
On the left side, the Tides Foundation serves a parallel function — a DAF and fiscal sponsor that channels donor funds to progressive organizations while preserving donor anonymity.
DonorsTrust and Tides are mirror images. Same legal structure. Same DAF mechanics. Same donor-anonymization outcome. Opposite political orientations. Both legal. Both working exactly as designed.
What could change this
There are policy proposals that would alter the DAF landscape. None have passed. Understanding why they haven’t is part of understanding the game.
1. Mandatory payout timeline. Currently, a DAF account has no legal obligation to distribute funds to working charities — ever. A donor can deposit $50 million, take the immediate tax deduction, and let the money sit in the account indefinitely. Proposals for a 5-year or 15-year mandatory payout have been introduced in Congress and have been defeated by lobbying from the DAF industry.
2. Donor disclosure to recipients. Currently, a recipient charity has no right to know who the actual donor is. Proposals to require DAF sponsors to disclose the account holder to the recipient have been opposed on First Amendment grounds.
3. Public reporting of individual DAF grants. Currently, DAF sponsors report total grants on their 990 but do not attribute individual grants to individual account holders in any public filing. Proposals for per-account reporting have been framed as threatening donor privacy.
The DAF industry is well-funded. By DAFs. The largest sponsors — Fidelity Charitable, Schwab Charitable, NPT — manage hundreds of billions and have substantial resources to oppose regulatory change. The policy landscape is unlikely to shift without sustained public pressure from citizens who understand the mechanism.
That is why we are teaching it.
The citizen’s move
Here is what you can do with what you just learned.
When you read a 990 for any organization you care about — the nonprofit you donate to, the charity your church supports, the advocacy group you follow — look at the list of major grants received. If you see “Fidelity Charitable,” “Schwab Charitable,” “DAFgiving360,” “National Philanthropic Trust,” “DonorsTrust,” “Donors Capital Fund,” “Tides Foundation,” “NCCF,” or any community foundation listed as a grantor, you are looking at DAF money.
You now know what that means. The name on the 990 is the name of the pipe, not the name of the person who turned on the faucet. The actual donor is invisible by law.
That does not mean the grant is illegitimate. Most DAF grants are perfectly ordinary charitable giving. But it does mean that you cannot evaluate the independence of that organization from its funders using public filings alone — because you do not know who the funders are.
Ask the question. File the FOIA. Write the letter to your representative asking why DAFs have no mandatory payout timeline. The action cards are on the Shadow Patriots side of this publication.
Or simply file the knowledge away and keep reading. Fluency is cumulative. By Module 10, you will read any 990 in America and know exactly what you are looking at.
CITIZEN ACTION: Module 3 here!
What comes next
Module 4 — “The Russian Doll” (Entity Laddering). How the (c)(3) + (c)(4) + PAC + LLC stack works. Same officers. Same donors. Same mission. Different filings. The donor just vanished. Now watch the operation multiply.
Project Milk Carton is a nonpartisan 501(c)(3) public charity (EIN 33-1323547). Case Study A is sourced from PMC Investigation OP-2026-0009 (BROKEN MIRROR). Case Study B is sourced from PMC Investigation OP-2026-0005 (EAGLE STRATEGY) and supplemented by published investigative reporting from ProPublica, the Capital Research Center, and public 990 filings. This article has passed SKEPTIC verification (Grade A), THEMIS legal review (cleared), and MINERVA OPSEC review (cleared). Evidence vault hash: see pinned comment.
Read the series: M0 “The Game You Were Never Taught” · M1 “The Tax Code That Became a Battlefield” · M2 “Reading the Map: Decoded” · Visit projectmilkcarton.org
Sources
IRS Form 990: Elev8hope Inc. (EIN 90-0806545), FY2024
IRS Form 990: DAFgiving360 / Schwab Charitable Fund
IRS Form 990: America First Policy Institute (EIN 85-4202763)
IRS Form 990: DonorsTrust Inc.
IRS Form 990: National Christian Charitable Foundation
IRS Form 990: New Venture Fund, Sixteen Thirty Fund, Hopewell Fund, Windward Fund
Florida Division of Corporations: Elev8hope Inc. filing history (3 administrative dissolutions)
National Philanthropic Trust, “2024 Donor-Advised Fund Report”
ProPublica Nonprofit Explorer: Arabella Advisors managed entities
Capital Research Center: “Big Money in Dark Shadows” (Arabella network documentation)
Congressional Research Service, “Donor-Advised Funds: Overview and Issues” (R46552)
PMC Investigation: Elev8hope financial forensics
PMC Investigation: Arabella network mapping
PMC Investigation: DonorsTrust/AFPI grant flow, NCCF DAF trace