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rom 13909 ‘Deparment ot te Teesury- noma Roverue Sence (December 2016) Tax-Exempt Organization Complaint (Referral) 1. Name of refered organization CENTER FoR GroBAr POLICY SaevTONys : Street address a LAST KNOWN: Boa © ST. NW, qs Oy Wr ASH tale [ae [FES ae i ofreteral 2, Organization's Employer Identification Number (EIN) = - = “4S HESeT+ : 3, Nature of violation Z) DirectorslOtcer/Peraons ar using income/asets for personal gain Z, Organization is engaged in commercial, oreo business activitios 1 ncome/Assets are being used to support illegal or terrorist activities |Z. Organization is involved in a political campaign (2) Organization is engaged in excessive lobbying activities J Orgarization rtused to disclose or provide a copy of Form 990 ~] Organization failed to report employment, income or excise tax liability properly Z Organization failed to file required federal tax returns and forms 5) Crganization engaged in deceptive or improper fundraising practices [] Other (describe) 4 Deals of violation a 7 Name(s) otpersonisinoved Sg EE ATTACHED ‘Organizational title(s) - Dates) Dollar amount(s) (ifknown) Description of activites 5. Submit information 7 Name NATIONAL LEGAL AND POLICY CENTER ‘Occupation ar Business Street address a . AST CARE WACHINGTN CT. a —o iy tu ———Teiat]ZiPeode | Teloshone number FALS CHUCK [VA 220% 703-237-1970 [5 1am concerned that | might face retaliation or retribution if my identity is disclosed 6, Submission and documentation: The completed form, along with any supporting documentation, may be mailed to IRS EO Classification, Mail Code 4910DAL, 1100 Commerce Street Dallas, TX 75242-1198, faxed to 214-419-5415 or emailed to ‘Your email submission of Form 13909 and attachments are not encrypted for security Ee ——eev——v—vwv'esr,,sosi_iW_ l OOO ‘Catalog Number 506144 www irs.90¥ Form 13909 (Rev. 12-2016) Co-Founder National Legal and 222" Policy Center yan Peter Flaherty, Chairman Kurt Christensen, Vice-Chairman “promoting ethics in public life” € —Michae! Falcone \ Richard F LaMountain David Wilkinson Since 1991 May 20, 2019 ‘The Honorable Charles P. Rettig Commissioner Internal Revenue Service 1111 Constitution Ave., NW Washington, DC 20224 RE: Center for Global Policy Solutions, EIN 45-4856194 Global Policy Solutions, LLC, EIN 56-2521323 Dear Commissioner Rettig: National Legal and Policy Center (NLPC) respectfully requests an immediate Internal Revenue Service (IRS) investigation into the operation of the Center for Global Policy Solutions (CGPS), a nonprofit corporation exempt from taxation pursuant to Internal Revenue Code (IRC) Section 501(c)(3), and its relationship with the similarly named Global Policy Solutions, LLC (GPS, LLC), a limited liability corporation registered in the District of Columbia. Public Charities are granted special privileges under federal tax law. Among these are exemption from most income taxation, and the ability to confer tax-deductibility to donor Contributions, In order to qualify for these benefits, a public charity must be exclusively “organized to engage in charitable activities, demonstrate minimum levels of public support, ensure that its lobbying activities are not a substantial part of it overall activities, ‘and strictly avoid intervening in the elections of public officials. Should a public charity fail to meet these basic terms, the law states that it is not qualified to remain tax-exempt. The IRS is solely responsible for enforcing provisions of the IRC. On its website, CGPS describes its mission: The Center for Global Policy Solutions drives society toward inclusion by advancing health, wealth, educational, and civic success for diverse populations. In its “Return of Organization Exempt From Income Tax,” (Form 990) for 2016, the latest publicly available annual tax return, CGPS describes its mission differently, but in equally vague terms The Center for Global Policy is a social change nonprofit dedicated to making policy work for people and iheir environment by advancing innovative and effective evidence-driven solutions to our world’s most critical challenges. 107 Park Washington Court * Falls Church, VA * 22046 703-237-1970 * fax 703-237-2090 * ‘The Honorable Charles P. Rettig May 20, 2019 Page Two ‘The president of CGPS is Maya Rockeymoore Cummings, an atypical nonprofit executive. Since 2008, she has been married to Representative Elijah Cummings (D- MD), Chairman of the House Oversight and Reform Committee. In December 2018, she was clected as Chair of the Democratic Party of Maryland, From October 2017 to January 2018, she was a candidate for Maryland Governor. Examination of publicly available documents, and the websites of CGPS and GPS, LLC, reveal that the two entities are closely related. Indeed, based on the circumstances cited below, the nonprofit CGPS and the for-profit GPS, LLC appear to operate almost as a single entity, allowing for an illegal private benefit for Maya Rockeymoore Cummings and her husband, who has a history of tax non-compliance. See Exhibit A. Go to: html “The Section 501(c)(3) requirement that a nonprofit must be exclusively organized for charitable purposes is the most important restriction under the IRC. Section 501(c)(3) strictly prohibits any inurement or private benefit. From the IRS website: A section 501(c\(3) organization must not be organized or operated for the benefit of private interests, such as the creator or the creator's family, shareholders of the organization, other designated individuals, or persons controlled directly or indirectly by such private interests. No part of the net earnings of a section 501(c)(3) organization may inure to the benefit of any private shareholder or individual. A private shareholder or individual is a person having a personal and private interest in the activities of the organization. Go to: hitps:// organizations/inurement-private-benefit-charitable-organizations In its investigation of CGPS and GPS, LLC, the IRS should examine: Shared leadership between CGPS and GPS, LLC. According to the 2016 CGPS Form 990, Maya Rockeymoore Cummings is a key employee, director and officer. According to the same Form 990, she worked an average of 40 hours per week, for a reportable compensation of $152,238. See Exhibit B. Her responsibilities at CGPS appear to be central to the group's operation. The CGPS website lists no other employees under the tab labeled “Staff.” On the 2016 CGPS Form 990, there are no employees listed in Part VII, Section A for “Highest Compensated Employees.” In its corporate filing in the District of Columbia, GPS, LLC identifies Maya Rockeymoore Cummings as its sole “Governor.” See Exhibit C. The GPS, LLC Website presents evidence of substantial commercial activity by GPS, LLC, which claims as clients AARP, YWCA, National League of Cities and several other large, well-heeled institutions.