David Armiak, research director and investigative journalist at the Center for Media and Democracy (CMD), notes in an interview that, increasingly, brand new nonprofits “that haven’t filed any IRS disclosure yet” are formed and start running issue ads or targeting candidates just weeks before voters go to the polls. Such pop-up groups—usually super PACs or 501(c)(4) nonprofits—typically don’t have to file with the IRS until late November, meaning they can hide the names of their funders until after an election has been held.
Moreover, Armiak says “donor advised funds [DAFs]”—a type of financial account created to make charitable donations—are “increasingly being used . . . by nefarious actors” to anonymously underwrite tax-exempt charities engaged in various sorts of issue advocacy.