Project 2025: The Heritage Foundation’s DAF Funded Campaign Intervention
I am not here to condemn Project 2025. I haven’t read it and don’t know enough about it as a substantive matter. There might even be some good proposals in it, for all I know. Here is a description straight from the horse’s mouth. The horse, in this case is The Heritage Foundation, a 501(c)(3) that is prohibited from endorsing or opposing a candidate for office:
The actions of liberal politicians in Washington have created a desperate need and unique opportunity for conservatives to start undoing the damage the Left has wrought and build a better country all Americans in 2025. It is not enough for conservatives to win elections. If we are going to rescue the country from the grip of the radical Left, we need both a governing agenda and the right people in place, ready to carry this agenda out on day one of the next conservative administration.
This is the goal of the 2025 Presidential Transition Project. The project will build on four pillars that will, collectively, pave the way for an effective conservative administration: a policy agenda, personnel, training, and a 180-day playbook. The project is the effort of a broad coalition of conservative organizations that have come together to ensure a successful administration begins in January 2025. With the right conservative policy recommendations and properly vetted and trained personnel to implement them, we will take back our government.
The 2025 Presidential Transition Project is being organized by The Heritage Foundation and builds off Heritage’s longstanding “Mandate for Leadership,” which has been highly influential for presidential administrations since the Reagan era. Most recently, the Trump administration relied heavily on Heritage’s “Mandate” for policy guidance, embracing nearly two-thirds of Heritage’s proposals within just one year in office. Paul Dans, former chief of staff at the Office of Personnel Management (OPM) during the Trump administration, serves as the director of the 2025 Presidential Transition Project. Spencer Chretien, former special assistant to the president and associate director of Presidential Personnel, serves as associate director of the project.
The gist of The Heritage Foundation’s communications is that readers should elect conservative candidates. Take a look at the website. HF is striving for a conservative “victory,” not just generally but in the very next presidential election. The complete name of “Project 2025” is “Project 2025: Presidential Transition Project.” In my quick perusal, I didn’t see any names mentioned but there ain’t but one conservative running for President right now. The Heritage Foundation does a whole lot of other things year round, but there is no de minimis exception for campaign intervention.
I bet the folks at The Heritage Foundation know and admit this; they just don’t give a rat’s ass whether Project 2025 is campaign intervention. Why should they. The prohibition against campaign intervention is likely unconstitutional. The Foundation likely supports SAFESPACE’s direct challenge to political restrictions in 501(c)(3) and doesn’t think the Service could win anyway.
All of what I think is campaign intervention is being funded through dark money donor advised funds, according to an interesting article in The Lever last week:
A significant portion of the money bankrolling the Heritage Foundation — the conservative think tank behind the sweeping “Project 2025” initiative to reshape the federal government if former President Donald Trump is reelected — comes from a growing network of shadowy charity groups run by the nation’s top financial firms that use a legal carve-out to keep their ultrawealthy donors hidden.
These groups, called donor-advised funds, have donated more than $18 million to the Heritage Foundation since 2020, according to a new Lever analysis and research by the Institute for Policy Studies shared exclusively with The Lever — and the amount is increasing.
In total, donor-advised funds held nearly $230 billion in assets in 2022, $52 billion of which was donated to nonprofits including the Heritage Foundation. Such funds now make up seven of the top 10 public charities in the country. What’s more, they have been found to distribute money to anti-government and hate groups at more than three times the rate of other charitable sources, according to a study published this May.
The rapid rise of donor-advised funds — charitable investment accounts run by finance giants like Fidelity Investments, Charles Schwab, and Vanguard — signals a new stage in the dark-money takeover of the political system. Wall Street is now helping the nation’s elite funnel vast amounts of cash to extremist causes with zero transparency or tax repercussions — and it’s spending millions lobbying Congress to keep it that way.
While private foundations like the Bill and Melinda Gates Foundation and the Ford Foundation are required to disclose all of their charitable donations and the recipients, wealthy philanthropists who want anonymity — and a tax break — can instead donate to a donor-advised fund.
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Meanwhile, the money donated to the Heritage Foundation is now supporting Project 2025, the organization’s political initiative that is pushing for a far-right reimagining of the country as part of a second Trump presidency. The plan’s many proposals include dismantling the National Oceanic and Atmospheric Association, barring U.S. citizens from receiving federal housing aid if they reside with noncitizen, disassembling services for LGBTQ+ individuals, and tracking confidential medical information of patients who seek abortion services, among many other endeavors.
darryll k. jones