donor think-tank project-2025 dark-money conservative 501c3 judicial tax-policy deregulation revolving-door
related: Project 2025 - The Blueprint They Followed Leonard Leo Koch Network - Charles Koch Federalist Society Trump Leo Judicial Pipeline Heritage Action for America DeVos Family Bradley Foundation
Who They Are
Conservative think tank founded in 1973 by Paul Weyrich and Edwin Feulner with seed funding from Joseph Coors. Operates as a 501(c)(3) research organization with $415 million in total assets (2023). Annual revenue crossed $100 million in 2023 — a 26% increase from pre-2022 levels, coinciding with the launch of Project 2025.
Heritage runs a three-entity political operation. The Foundation itself produces policy research and personnel pipelines. Heritage Action for America (501(c)(4), founded 2010) does lobbying and grassroots mobilization through ~20,000 “Sentinels.” The Sentinel Action Fund (Super PAC, launched 2022) handles direct electoral spending — $13 million in the 2022 midterms alone.
The organization’s structural function is not research. It is personnel placement and policy pre-fabrication. Heritage doesn’t just recommend policy — it writes the executive orders, trains the appointees, and tracks implementation. Project 2025 made this explicit with its four pillars: a 920-page policy guide, a database of 30,000+ vetted applicants for federal positions, a Presidential Administration Academy to train them, and a 180-day action playbook for the first six months.
Quote
No other Washington institution has “that kind of footprint” in a presidential transition. — CNN Politics, January 2017, describing Heritage’s role in Trump 1.0 staffing
What They Want
Heritage’s policy agenda has been remarkably consistent for 50 years. The specifics rotate; the structural goals don’t.
Regulatory capture: Gut the administrative state’s capacity to regulate industry. EPA deregulation, OSHA enforcement collapse, NLRB gutting, CFPB weakening — all appear in the Mandate for Leadership documents across multiple editions.
Tax architecture for capital: The Tax Cuts and Jobs Act (2017) was Heritage’s signature policy win. Stephen Moore, Heritage’s tax expert, was a key architect. Heritage hosted Trump, Paul Ryan, and Ways and Means Chair Kevin Brady during the design phase.
Judicial pipeline: Heritage co-produced (with the Federalist Society) the list of 21 Supreme Court nominees that Trump adopted in 2016. John Malcolm, director of Heritage’s Meese Center, prepared the list. Neil Gorsuch came directly from it.
Personnel control: Schedule F — reclassifying tens of thousands of federal employees as at-will — originated in Heritage policy papers and was implemented in Trump’s first term before Biden reversed it. Project 2025 builds the infrastructure to do it again, permanently.
Defense spending: Consistent advocacy for increased military budgets, aligned with defense contractor donor interests.
Who Funds Them
Heritage does not disclose individual donors (501(c)(3) organizations are not required to). But investigative reporting and foundation filings have mapped the funding network:
| Donor | Amount | Period | Source |
|---|---|---|---|
| Sarah Scaife Foundation | $18M+ | 1985-2023 | DeSmog |
| Koch network (Lambe Foundation + DonorsTrust) | $5.7M+ | 1998-2024 | DeSmog |
| Lynde and Harry Bradley Foundation | $5.9M+ | 1998-2024 | DeSmog |
| Bradley Impact Fund | $50M+ to 29 Project 2025 advisory groups | 2020-2024 | DeSmog |
| Coors family | Founding funders | 1973-present | Historical record |
| DeVos family | Undisclosed | Ongoing | InfluenceWatch |
| DonorsTrust / Donors Capital Fund | $500K+ to Heritage directly | 2010-2024 | DeSmog |
Money
The Bradley Impact Fund alone pushed $50 million to 29 Project 2025 advisory board organizations since 2020. Heritage’s own 2022 grants directed 58% ($965,000 of $1.67 million) to Project 2025 advisory organizations. The fundraising surge coincided precisely with the project’s launch — revenue jumped 26% from pre-2022 baselines to $100.9 million in 2023.
What They’ve Gotten
The Revolving Door — By the Numbers
Trump 1.0 (2017-2021): At least 66 Heritage employees and alumni were hired into the administration. Heritage maintained a database of ~3,000 vetted conservatives built since 2014 specifically for this purpose.
Trump 2.0 (2025-present): At least 31 individuals with Project 2025 connections appointed, nominated, or confirmed to administration positions, including:
- Russell Vought — OMB Director (key Project 2025 architect)
- Peter Navarro — Senior Counselor for Trade & Manufacturing (Mandate author)
- Tom Homan — Immigration enforcement (listed contributor)
Heritage rehires after Trump 1.0: The revolving door swings both ways. When Trump left office, Heritage absorbed senior officials to keep them in the network:
- Ken Cuccinelli (Deputy DHS Secretary)
- Mark Morgan (Acting CBP Commissioner)
- Chad Wolf (DHS)
- Dustin Carmack (Chief of Staff to DNI)
- Tim Murtaugh (USDA Communications / Trump campaign)
Contradiction
Heritage presents itself as a nonpartisan research institution and maintains 501(c)(3) tax-exempt status on that basis. In practice, 54% of Project 2025’s 267 contributors previously worked in Trump’s first administration, campaign, or transition. Heritage contributed $1 million directly to the 2024 Republican National Convention. The “research” is the job application.
Policy Implementation Tracker
| Heritage Recommendation | Implementation | Outcome |
|---|---|---|
| Tax Cuts and Jobs Act design | 2017 | $1.9T in cuts, corporate rate 35% → 21% |
| Supreme Court nominee list | 2016-2020 | Gorsuch, Kavanaugh, Barrett confirmed |
| Schedule F civil service reclassification | EO 2020, reversed 2021, reimplemented 2025 | Tens of thousands of federal workers at risk |
| EPA deregulation package | 2017-2020, expanded 2025 | Dozens of environmental rules rolled back |
| USMCA (NAFTA rebrand) | 2018-2020 | Heritage-influenced renegotiation |
| Project 2025 personnel pipeline | 2025-present | 31+ appointees, 30,000+ applicant database |
Temporal Mapping — The Project 2025 Pipeline
| Date | Event | Amount/Scale | Outcome |
|---|---|---|---|
| 2022 | Project 2025 launched under Paul Dans | — | 920-page Mandate, 30,000 applicant database |
| 2022 | Heritage grants $965K to P2025 advisory orgs | $965K | 58% of all Heritage grant-making |
| 2022-2023 | Revenue surges 26% | $95M → $100.9M | Fundraising machinery activated |
| 2024 | Heritage donates to RNC Convention | $1M | Direct partisan spending |
| 2024 | Bradley Impact Fund pushes to P2025 network | $50M+ | 29 advisory organizations funded |
| Jan 2025 | Trump inaugurated | — | Project 2025 implementation begins |
| 2025 | 31+ P2025-connected officials placed | — | Russell Vought (OMB), Navarro, Homan |
| 2025 | Schedule F reimplemented | — | Federal workforce restructuring |
| Dec 2025 | Heritage staff exodus to Pence group | 12+ staff | Internal fracture over antisemitism concerns |
Class Analysis
Heritage Foundation is the institutional machinery that converts donor-class policy preferences into government action. It is not a think tank that happens to influence policy. It is a personnel and policy factory that maintains tax-exempt status.
The structural function: billionaire foundations (Scaife, Koch, Bradley, Coors, DeVos) fund Heritage. Heritage produces policy documents and trains personnel. Those personnel enter government and implement the policies. When they leave, Heritage rehires them, keeping the network intact until the next administration.
Money
The ROI calculation for Heritage donors is staggering. The Koch network invested $5.7 million in Heritage over 25 years. Heritage-aligned policy wins include the Tax Cuts and Jobs Act (saving Koch Industries an estimated $1-1.4 billion annually), Chevron deference elimination, EPA deregulation across two administrations, and NLRB gutting. Even attributing only a fraction of these outcomes to Heritage, the return exceeds 100x.
The December 2025 staff exodus — 12+ senior employees leaving for a Mike Pence-founded group over antisemitism concerns — reveals a secondary dynamic. Heritage’s power depends on maintaining the appearance of principled conservatism. When the organization’s alignment with Trump becomes too politically toxic for some staff, the network fractures. But the personnel database, the policy documents, and the donor relationships persist.
Heritage Action’s scorecard system deserves specific attention. By rating every member of Congress on Heritage-defined metrics and mobilizing 20,000 grassroots “Sentinels” to pressure them, Heritage doesn’t just recommend policy — it enforces compliance. Legislators who deviate from Heritage positions face primary challengers, negative scorecard ratings, and grassroots pressure campaigns.
Connected Policy Areas
Sources
- OpenSecrets: Heritage Foundation summary (Tier 1)
- OpenSecrets: Heritage Foundation lobbying (Tier 1)
- OpenSecrets: Heritage Action political spending (Tier 1)
- OpenSecrets: Heritage Action independent expenditures 2018 (Tier 1)
- ProPublica Nonprofit Explorer: Heritage Foundation 990 filings (Tier 1)
- Heritage Foundation: Consolidated Financial Report 2024 (Tier 1)
- Project 2025: Mandate for Leadership full text (Tier 1)
- Heritage Foundation: Tax Cuts and Jobs Act impact timeline (Tier 1)
- Heritage Foundation: Four Trump Cabinet Members Now Call Heritage Home (Tier 1)
- DeSmog: 6 Billionaire Fortunes Bankrolling Project 2025 (Tier 2)
- Media Matters: Heritage Gave $1M to Trump Convention (Tier 2)
- Media Matters: Trump Personnel with Project 2025 Ties (Tier 2)
- NBC News: Donations Surged to Groups Linked to Project 2025 (Tier 2)
- AFGE: Trump Administration Packed with Project 2025 Architects (Tier 2)
- Newsweek: Project 2025 Contributors in Trump Administration (Tier 2)
- PBS: Tracking Project 2025 Implementation (Tier 2)
- NPR: Heritage Foundation Staff Walkout (Tier 2)
- Washington Post: Heritage staffers walk out amid latest strife at MAGA institution (Tier 2)
- Bloomberg Government: Heritage Action Turnover Prompts Lobbying Drop (Tier 2)
- Slate: How the Federalist Society Became SCOTUS Selector (Tier 2)
- Campaign Legal Center: CLC Sues Heritage Action for Disclosure Violations (Tier 2)
- Revolving Door Project: Heritage Lays Foundation for Schedule F (Tier 2)
- The Conversation: Heritage Foundation’s Over 50-Year History (Tier 2)
content-readiness:: ready