Charitable and Political PAC Commingling
Last updated: November 21, 2025
Status: The Trump Foundation was dissolved under court supervision after findings of misuse of charitable assets. Subsequent scrutiny has focused on Trump-aligned political committees and whether certain expenditures—especially legal fees and spending at Trump-owned properties—reflect blurred boundaries between political activity, personal benefit, and nonprofit rules. No criminal charges have been brought regarding PAC spending, but watchdogs and media continue to monitor the issue.
Summary
The commingling of charitable funds and political resources has been a recurring theme in investigations involving entities connected to Donald J. Trump. The clearest example is the New York Attorney General’s civil action against the Trump Foundation, which concluded that the charity had been used for political and personal purposes. That case ended with a court-ordered $2 million payment, governance restrictions, and supervised dissolution.
Following the foundation’s closure, attention shifted to Trump-aligned political committees, especially the Save America leadership PAC and various joint fundraising committees. Leadership PACs are permitted to spend money more freely than traditional campaign committees, including on legal expenses, but watchdog groups have raised concerns about donor-expectation issues, payments to Trump-owned properties, and the scale of legal spending across 2021–2025. These concerns highlight the persistent tension between legality, transparency, public ethics expectations, and the practical realities of political fundraising in a modern, personality-driven political environment.
The Trump Foundation Findings
New York’s 2018 civil action against the Donald J. Trump Foundation alleged “persistent illegality” and described the charity as operating, at times, as a personal and political funding mechanism. Among the examples cited were payments that benefited Trump-owned businesses, charitable events that served political purposes, and failures of board oversight.
In 2019, the New York Supreme Court ordered Donald Trump to pay $2 million in damages for misuse of charitable funds, with the money directed to a group of nonprofit organisations. The settlement also imposed governance training requirements on Trump’s children before they could lead other New York charities. The foundation itself was dissolved under judicial supervision, with remaining assets distributed to approved charities.
Coverage by national outlets described the court’s conclusions, the agreed-upon financial remedies, and the final wind-down of the foundation’s operations. The case became a widely cited example in nonprofit-law circles because it illustrated how charitable entities can violate rules on private inurement, political activity, and fiduciary oversight.
Broader Context — Overlap Between PACs and Nonprofit Activity
After the foundation’s dissolution, fundraising efforts shifted primarily to political committees. These included Save America (a leadership PAC), MAGA Inc., and joint fundraising structures with the Republican National Committee. Each committee has distinct regulatory obligations under federal campaign-finance law, but watchdogs argue that the ecosystem as a whole reflects a pattern in which political and personal interests are intertwined.
Leadership PACs, unlike campaign committees, are not subject to the strict “personal use” prohibition. This regulatory gap means that funds can legally be used for a wide range of expenses, including some that voters may not expect, such as attorneys’ fees unrelated to campaigning. Reports from 2023 and 2024 showed tens of millions of dollars being routed to law firms representing Trump in civil, criminal, and congressional investigations. These expenditures are disclosed but often raise ethical questions about donor intent and whether political committees are effectively subsidising personal legal battles.
Watchdog organisations have also documented recurring payments by Trump-aligned committees to Trump-owned properties. Such transactions are permissible if they are at or below fair-market value, but critics note that the overlap between political spending and private businesses creates optics problems and potential conflicts of interest.
Examples of Potential Commingling
Charitable Events with Campaign Elements (2016)
One of the most well-known examples occurred during the 2016 presidential primaries, when a charitable event for veterans in Iowa coincided with campaign activities. The New York Attorney General later cited this as an instance where charitable assets were used to benefit a political campaign, violating nonprofit law. The foundation funds disbursed at the event became part of the broader case that ended in the foundation’s dissolution.
PAC Funds for Legal Fees
Political committees affiliated with Trump have paid extensive legal fees since 2021, according to analyses of Federal Election Commission filings. These outlays have covered representation in criminal cases, civil lawsuits, congressional inquiries, and other legal matters. While leadership PAC rules allow such payments, the volume of spending has raised public debate over whether contributors understood their donations would be used predominantly for legal defence rather than campaign activity.
Payments to Trump-Owned Venues
Reports by watchdog groups indicate that Trump-connected political committees continued to spend money at Trump hotels, golf clubs, and other venues. The legality of such expenditures depends on paying fair-market rates, but the recurring nature of these payments has been scrutinised for potential circularity: political donors fund committees, committees pay Trump-owned businesses, and the financial benefit accrues to Trump or his associated entities.
Legal and Ethical Implications
The Trump Foundation case serves as a landmark example in enforcement actions involving misuse of charitable funds. It established that charitable organisations and their leaders can face significant consequences for private inurement, political use, or inadequate board governance. The case is now frequently referenced in academic texts examining nonprofit compliance.
The situation with political committees is different. Leadership PACs have far fewer restrictions and operate within a legal framework that allows broad discretion. Yet ethical concerns remain. Critics argue that donors may not be clearly informed when contributions support legal defence costs rather than political mobilisation. Others contend that payments to businesses owned by political figures undermine confidence in the integrity of campaign-finance systems.
For Trump, the scrutiny highlights risks that arise when personal branding, business interests, charitable claims, and political fundraising all intersect. Even when conduct is technically permissible, the optics can carry reputational and political costs.
Key Takeaways
Trump Foundation dissolution: A court found misuse of charitable assets and ordered $2 million in damages, with dissolution supervised by the New York Attorney General.
PAC legal spending: Trump-aligned PACs have spent tens of millions on attorneys and related expenses since 2021.
Payments to Trump properties: Political committees continue to direct funds to Trump-owned venues, raising transparency and ethics concerns.
Regulatory gap: Leadership PACs face fewer personal-use limits than campaign committees, creating recurring controversies over donor expectations.
Sources
New York Attorney General – Court Order and Foundation Dissolution (Nov 7, 2019)
Associated Press – “Judge fines Trump $2 million for misusing charity foundation” (Nov 8, 2019)
OpenSecrets – Save America PAC Profile
OpenSecrets – “Trump political operation steers $130M to legal fees” (Aug 4, 2023)
CREW – “Political committees’ spending at Trump properties” (May 15, 2025)