think-tank conservative project-2025 dark-money revolving-door idea-laundering regulatory-capture judicial-pipeline 501c3

related: Heritage Foundation (donor node) · Koch Network - Charles Koch · Charles Koch · Bradley Foundation · Leonard Leo · Federalist Society


Who They Are

The Heritage Foundation is a Washington D.C.-based 501(c)(3) conservative policy organization founded in 1973 by Paul Weyrich and Edwin Feulner, with seed funding from beer magnate Joseph Coors. It is the most influential conservative think tank in the United States — and “think tank” is the wrong frame. Heritage is a policy factory, a personnel pipeline, and a compliance enforcement mechanism dressed in the language of scholarship.

Annual revenue reached $133.9 million in 2024, up from $72.2 million in 2011 — an 85% expansion over 13 years. The acceleration was sharpest in 2022-2023, coinciding exactly with Project 2025’s launch. Total assets: $333.6 million (2024). Donor base: approximately 600,000. Staff: 300+. President since 2021: Kevin Roberts, compensated $953,920 annually in 2023.

Heritage operates as a three-entity political machine: the Foundation (501(c)(3)) produces policy research and trains personnel; Heritage Action for America (501(c)(4), founded April 2010) handles lobbying and grassroots mobilization through ~20,000 “Sentinel” activists who pressure members of Congress; and the Sentinel Action Fund (Super PAC, launched 2022) runs direct electoral spending — $13 million in the 2022 midterms alone.

The organization’s Mandate for Leadership — first published in 1981 — is the authoritative right-wing policy blueprint for Republican administrations. Reagan adopted roughly 60% of its recommendations in his first year. The 2025 edition, produced as the centerpiece of Project 2025, is 920 pages and was authored by 400+ contributors, 54% of whom previously worked in Trump’s first administration.

Money

Heritage doesn’t produce independent research. It produces pre-assembled policy for donors who need intellectual cover. The Mandate for Leadership is not written and then adopted — it is adopted and then written. The donors who fund Heritage have consistent, documented policy preferences. Heritage produces research that recommends those exact policies. Politicians cite that research as “independent analysis.” The laundering is the function. The Center for Data Analysis has never produced an analysis finding that a tax cut is harmful and has never been subjected to peer review.


Who Funds Them

Heritage is a 501(c)(3) and does not publicly disclose individual donors. But foundation grant filings, IRS 990 documents, and investigative reporting have mapped the funding network with significant specificity.

Founding Donors and Major Foundations

DonorDocumented AmountPeriodSource
Sarah Scaife Foundation$30M+1973–2024InfluenceWatch, DeSmog
Lynde and Harry Bradley Foundation$16M+ to Heritage1985–2024Vipul Naik donation database
Koch network (all vehicles)$6.1M+ direct1998–2024DeSmog, SourceWatch
Coors family (founding + ongoing)$8M+ (direct + DonorsTrust)1973–presentHistorical records, DonorsTrust
DeVos family$5M+ documented2000–presentConservative Transparency, SourceWatch
DonorsTrust / Donors Capital Fund$2.9M direct2010–2024SourceWatch, ProPublica
Fidelity Charitable Gift Fund$6.3M2017–2022SourceWatch
ExxonMobil$870K1990s–2018Climate Investigations Center
Lockheed Martin$341K2000–2008Leaked emails, Occupy.com
All donor-advised funds (combined)$18M+2020–2024Jacobin/The Lever

The 2023 IRS 990 shows Heritage’s own grant-making directed 58% of its $1.67 million in grants ($965,000) to Project 2025 advisory organizations — Heritage funding its own political network while maintaining tax-exempt research status.

Dark money conduits — DonorsTrust and Donors Capital Fund — are specifically used to obscure the original donor identity. A billionaire can donate to DonorsTrust and direct funds to Heritage without any public trace of that relationship. This is the structural purpose of the dark money conduit system. DonorsTrust’s board includes John Von Kannon, Vice President of the Heritage Foundation, creating a direct governance interlocking directorate.

Money

Total documented funding from just four donor networks (Scaife, Bradley, Koch, DonorsTrust): $60M+ over 25 years to Heritage directly, plus $50M+ through Bradley Impact Fund to the broader Project 2025 network. Heritage’s revenue jumped 26% in 2022-2023, the precise period when Project 2025 launched its staffing database and Mandate for Leadership drafting. The fundraising surge was not coincidental — the donors who benefit from Project 2025 policy paid for Project 2025 policy to be written.

Contradiction

Heritage Foundation claims 501(c)(3) status as a nonpartisan research organization. In 2024, Heritage donated $1 million directly to the Republican National Convention — a nakedly partisan expenditure. The Sentinel Action Fund (Heritage’s own Super PAC) spent $13 million in the 2022 midterms on explicitly partisan electoral campaigns. Heritage Action’s congressional scorecard exists to enforce party-line voting, not to promote nonpartisan research. The “nonpartisan” designation is a tax-status fiction that saves Heritage’s donors tens of millions in taxes annually.

Koch Network

Koch Industries — the second-largest privately held company in America, with core businesses in oil refining (Flint Hills Resources), chemicals (Invista), paper (Georgia-Pacific), and pipeline infrastructure — has funded Heritage through multiple vehicles since at least 1998:

SourceAmountPeriod
Claude R. Lambe Foundation$4.8 million1998–2012
Claude R. Lambe Foundation (single year)$650,0002012
Charles Koch Foundation$631,5542014–2020
Charles Koch Institute$624,0002018–2020
Freedom Partners (Koch) to Heritage Action$500,0002013
Stand Together Trust$200,0002022
Total Koch network to Heritage$6.1M+1998–2024

Beyond direct Heritage funding, Koch’s David Koch-linked foundations gave more than $165 million total to climate-denying organizations from 1986 to 2018, including $23 million to Project 2025 advisory groups. Koch’s Americans for Prosperity (AFP) and Heritage coordinate on state-level campaign strategy.

Corporate Donors

ExxonMobil: $870,000 in documented grants, including $25,000 earmarked specifically for climate change programs, per the Climate Investigations Center. Heritage defended ExxonMobil against state attorney general climate investigations in 2016 commentary calling the investigations “a political mob shakedown.”

Pharmaceutical companies (2006): Pfizer, Johnson & Johnson, GlaxoSmithKline, Novartis, and Bristol-Myers Squibb Foundation each gave over $100,000. PhRMA gave Heritage Action $37,500 in 2018 and Heritage Foundation $212,500 in 2018–2019 while Heritage opposed pharmaceutical price controls.

Lockheed Martin: $341,000 through at least 2008, with Heritage officials meeting with Lockheed executives “on nearly a monthly basis” in 2008–2009 and publishing reports supporting the F-22 Raptor after the Pentagon recommended cutting it.

Shell USA Company Foundation: Documented donor to Heritage and other Project 2025 advisory organizations, per DeSmog’s 2024 investigation of fossil fuel philanthropy.

DonorsTrust: The Dark Money ATM

DonorsTrust (founded 1999) and Donors Capital Fund are donor-advised funds functioning as anonymizing pass-through layers. DonorsTrust has distributed over $1.5 billion since founding, with massive anonymous contributions in recent years: $427 million (2021), $426 million in stock transfers, and $77 million in additional 2021 gifts. [Mother Jones first identified DonorsTrust as the “dark money ATM of the conservative movement.“]

Known major contributors through DonorsTrust include Charles Koch ($2 million in 2010 alone), the Richard and Helen DeVos Foundation ($2.5 million), the Bradley Foundation ($650,000 in identified gifts), and the Adolph Coors Foundation ($5.9 million in recent years).

Documented flow from DonorsTrust and Donors Capital Fund to Heritage directly totals approximately $2.9 million (2010–2021). In 2021 alone, DonorsTrust gave Heritage $361,000. All donor-advised funds gave Heritage more than $18 million since 2020, with contributions growing from $2.7 million (2022) to $4.3 million (2023).

Heritage Foundation Financial Profile

Heritage’s revenue growth reflects the expanding scale of conservative investment in policy infrastructure:

Fiscal YearTotal RevenueContributionsNet Assets
2011$72,170,983$65,687,562$143,231,547
2015$92,008,484$88,804,116$226,283,115
2019$122,861,202$116,992,003$321,496,833
2020$119,134,479$65,877,330$331,754,148
2021$101,783,032$75,262,071$367,272,162
2022$106,329,524$95,083,025$331,987,871
2023$100,963,350$97,801,739$347,683,824
2024$133,868,147$106,031,026$333,560,920

Historical context: 1973 founding budget: $250,000; 1976 annual budget: $1 million (with Scaife providing $420,000 — 42% of total); 1981: $5.3 million; early 1990s: ~$25–30 million; 2024: $133.9 million. In most years, 90–97% of revenue comes from donations. Heritage does not disclose individual donors.


What They Produce

Mandate for Leadership (1981–present): The flagship product. A comprehensive policy blueprint issued before each Republican administration, covering every executive branch agency and major policy area. The 2025 edition is 920 pages with 400+ contributors, 54% of whom previously worked in Trump’s first administration.

Project 2025 (2022–2025): Heritage’s most ambitious output, with four components: (1) the 920-page Mandate for Leadership policy guide; (2) a database of 30,000+ vetted conservative applicants for federal positions; (3) the Presidential Administration Academy, a training program for incoming government personnel; and (4) a 180-day action playbook for the first six months of a new administration. Heritage spent $22 million on the staffing component alone.

Heritage Action Scorecard: A congressional compliance mechanism. Every member of Congress receives a Heritage-defined score based on their votes. Low-scoring members face primary challengers, grassroots pressure from 20,000 “Sentinels,” and negative campaign material. The scorecard measures alignment with Heritage’s (i.e., its donors’) preferred positions.

Supreme Court Nominee Lists: Co-produced with the Federalist Society. Heritage’s Meese Center for Legal and Judicial Studies compiled the list of 21 SCOTUS nominees that Trump officially adopted in 2016. All three Trump SCOTUS appointments came from the list.

Model Legislation and Regulatory Frameworks: Heritage produces draft regulatory rollback language, model executive orders, and legislative proposals adopted verbatim by sympathetic administrations. Schedule F originated in Heritage policy papers before becoming Trump Executive Order 13957.

Project 2025 — Implementation Score (February 2026): By February 2026, the Trump administration had initiated or completed 53% of Project 2025’s domestic administrative policy agenda — 283 of 532 recommended actions in the first 12 months. This outpaces the first Trump administration’s comparable period.


The Policy Pipeline

Heritage’s policy pipeline has five stages:

Stage 1 — Commission the research. Donor gives to Heritage (often through DonorsTrust to obscure the trail). Heritage assigns staff to produce a policy paper recommending the donor’s preferred outcome. The paper is written in academic language with footnotes.

Stage 2 — Distribute the paper. Heritage sends the paper to sympathetic members of Congress, their staff, and executive branch officials. Heritage Action’s 20,000 grassroots activists amplify the recommendations publicly. The Heritage scorecard signals to legislators that their compliance will be tracked.

Stage 3 — Place the personnel. Heritage’s staffing database matches vetted conservatives to open positions in the executive branch, regulatory agencies, and congressional staff roles. These are people trained at Heritage’s Presidential Administration Academy who carry Heritage’s policy agenda into government.

Stage 4 — Implement the policy. Heritage alumni in government implement the recommendations from Stage 1. When journalists ask why a regulation was rolled back, the official cites the Heritage paper — “independent research” — as justification.

Stage 5 — Absorb the alumni. When the administration ends, Heritage rehires the government officials to keep them in the network until the next administration. The network persists regardless of electoral outcomes.


The Policy Kill Map — Healthcare

The Individual Mandate Irony: Heritage invented the individual health insurance mandate in October 1989. Heritage’s Director of Domestic Policy Studies, Stuart M. Butler, presented “Assuring Affordable Health Care for All Americans,” containing the exact language: “Mandate all households to obtain adequate insurance … This mandate is based on two important principles. First, that health care protection is a responsibility of individuals, not businesses.” The mandate was adopted by Republican Senator John Chafee’s 1993 HEART Act, Mitt Romney’s 2006 Massachusetts reform, and ultimately the Affordable Care Act of 2010 — at which point Heritage reversed course entirely and filed legal briefs arguing its own creation was unconstitutional. Stuart Butler wrote in February 2012 that “Heritage and I actively oppose the individual mandate, including in an amicus brief filed in the 11th Circuit Court of Appeals.”

Opposition to the Clinton Health Security Act (1993): When President Clinton unveiled his 1,342-page Health Security Act in November 1993, Heritage launched the most comprehensive institutional response of any organization. Heritage scholars produced “A Guide to the Clinton Health Plan” (Moffit, November 1993), characterizing the proposal as “a massive top-down, bureaucratic command-and-control system” that would cost 600,000 to 3.1 million jobs. Heritage promoted the Nickles-Stearns bill (S. 1579) as its alternative and hired the Lewin Group to model finances. The Health Security Act was declared dead by Senate Majority Leader George Mitchell on September 26, 1994.

Opposition to the ACA: Heritage’s campaign spans fifteen+ years through publications, litigation, congressional scorecarding, and direct opposition. Key publications include “Obamacare: Impact on the Uninsured” (Moffit, April 2010), “Obamacare and the Individual Mandate: Violating Personal Liberty and Federalism” (Moffit, January 2011), and “Year Six of the Affordable Care Act” (Moffit et al., April 2016). Heritage Action for America, launched April 2010 specifically to fight the ACA, issued legislative scorecards rating every vote on repeal and modification. When the House produced the American Health Care Act in 2017, Heritage Action opposed it from the right, arguing it did not go far enough. Heritage filed amicus briefs in NFIB v. Sebelius challenging the individual mandate’s constitutionality; the Supreme Court’s 2012 ruling accepted Heritage’s position on Medicaid coercion.

Medicare for All and Single-Payer Opposition: Heritage’s opposition spans three decades. When Senator Bernie Sanders introduced Medicare for All in 2017, Heritage responded with “The Ugly Consequences of Single-Payer Health Care” (Moffit, November 2017), projecting a full 10-year cost of $24.7 trillion to $32 trillion and arguing 71% of working families would pay more than under current law. Heritage’s Special Report No. 219, “How ‘Medicare for All’ Harms Working Americans” (Haislmaier and Hall, November 2019), modeled both the 2019 House and Senate bills and concluded average disposable income for all households would decline $5,671 per year. Neither Medicare for All nor a public option has reached a floor vote in either chamber.

Pharmaceutical Price Controls: Heritage has consistently opposed government drug price controls using framing identical to pharmaceutical industry lobbying campaigns while receiving documented payments from those same donors. “Why Pelosi’s Drug Price Control Scheme Would Be a Poison Pill to Innovation” (September 2019) opposed the “Lower Drug Costs Now Act” as “an unprecedented exercise of raw government power.” When the Inflation Reduction Act allowed Medicare to negotiate drug prices beginning 2026, Heritage opposed it as “replacing private sector negotiations with price controls.”

Pharmaceutical and Insurance Industry Donors:

DonorAmountYear(s)Type
PhRMA$37,5002018Grant to Heritage Action
PhRMA$212,5002018–2019Grant to Heritage Foundation
Pfizer>$100,0002006Corporate donation
Johnson & Johnson>$100,0002006Corporate donation
GlaxoSmithKline>$100,0002006Corporate donation
Novartis>$100,0002006Corporate donation
Bristol-Myers Squibb Foundation>$100,0002006Corporate donation

Medicaid Expansion Opposition: Heritage characterized Medicaid as “a broken welfare program that promises more than it can deliver” (Owcharenko, April 2002) and the ACA’s expansion to 138% of federal poverty level as “Millions of Americans Dumped into Medicaid.” Heritage’s block grant alternative was included in every Republican repeal proposal from 2012 through 2017; all failed. Heritage supported Trump’s 2020 “Healthy Adult Opportunity” block grant guidance.

The Policy Kill Map — Climate and Environment

Kyoto Protocol Opposition (1997): Heritage published its first comprehensive opposition document in October 1997: “The Road to Kyoto: How the Global Climate Treaty Fosters Economic Impoverishment and Endangers U.S. Security.” A 1999 report, “Squandering the Surplus: $11 Billion on the Unratified Kyoto Protocol,” cited astrophysicist Sallie Baliunas and the Oregon Petition to dispute climate science, projecting Kyoto restrictions would reduce U.S. GDP by “as much as $2 trillion between 2008 and 2012.” Heritage’s PolicyExperts.org database listed prominent climate skeptics including Patrick Michaels, Sallie Baliunas, and Fred Singer.

Cap-and-Trade: The $9.4 Trillion Lie: When the House considered Waxman-Markey in 2009, Heritage’s Center for Data Analysis published “The Economic Consequences of Waxman-Markey” (August 6, 2009), projecting aggregate GDP losses of $9.4 trillion from 2012 to 2035. The Congressional Budget Office’s estimate was $175 per year per family in 2020. Heritage’s figure — approximately $1,870 per year — was roughly eleven times the CBO’s estimate. Heritage attacked the CBO directly in “CBO Grossly Underestimates Cost of Cap and Trade” (July 2009). The World Resources Institute published a detailed rebuttal finding Heritage’s methodology “highly misleading” — summing 20 years of annual GDP impacts, using outdated EIA clean energy cost forecasts, and systematically ignoring economic benefits. Waxman-Markey passed the House but failed in the Senate in 2010. Heritage’s $9.4 trillion figure was deployed extensively in Republican opposition messaging.

Clean Power Plan (2015): The EPA’s Clean Power Plan — the first-ever federal limits on carbon dioxide from existing power plants — was proposed in August 2015 and immediately targeted by Heritage’s sustained research assault. “The Many Problems of the EPA’s Clean Power Plan and Climate Regulations: A Primer” (Nicolas Loris, Backgrounder No. 3025, July 2015) projected by 2035: an average employment shortfall of nearly 400,000 jobs, manufacturing employment shortfall of 200,000 jobs, aggregate GDP loss of more than $2.5 trillion, and total income loss of more than $20,000 per family of four. Heritage noted EPA’s own models showed the plan would avoid less than 0.02°C warming over 85 years. The Supreme Court stayed the Clean Power Plan in February 2016 before it took effect. The Trump administration repealed it in 2019; Heritage celebrated.

Paris Climate Agreement (2016-2017): Heritage’s “Consequences of Paris Protocol: Devastating Economic Costs, Essentially Zero Environmental Benefits” (Kevin D. Dayaratna, Nicolas Loris, and David W. Kreutzer, April 13, 2016) used Heritage’s Energy Model to project a $2.5 trillion aggregate GDP loss by 2035 and an average annual employment shortfall of 400,000 jobs. Most remarkably, Heritage argued that the social cost of carbon could be negative — that under “reasonable assumptions,” CO₂ emissions are a net economic benefit. Heritage issued a press release after Trump’s June 1, 2017 withdrawal announcement explicitly claiming credit, noting that Trump cited Heritage economic projections in a speech during his first 100 days. The World Resources Institute’s March 2017 rebuttal documented that Heritage’s $2.5 trillion figure represented less than 1% of cumulative U.S. GDP when spread across 20 years, used outdated clean energy cost forecasts, and contained no analysis of economic benefits of avoiding climate disruption.

Green New Deal (2019): Heritage’s response to the Green New Deal resolution (introduced February 2019) involved Heritage’s most revealing analytical failure: the Heritage Energy Model literally crashed. In “Assessing the Costs and Benefits of the Green New Deal’s Energy Policies” (Dayaratna and Loris, Backgrounder No. 3427, July 2019), researchers modeled carbon taxes up to $300 per ton. Beyond that level, Heritage acknowledged, the model “crashed” and could not generate outputs. Even at $300 carbon tax, Heritage projected a GDP loss of $15 trillion by 2040, 1.1 million jobs per year lost, and cumulative income losses of $165,000 for a family of four — with temperature reduction of “less than 0.2 degree Celsius cooler by the year 2100.” Heritage declared: “The U.S. could cut its carbon-dioxide emissions 100 percent, and it wouldn’t make a difference in averting temperature increases or sea level rise.” The Green New Deal resolution never advanced to a vote in the Senate.

Fossil Fuel Funding Pipeline: The overlap between Heritage’s climate denial research and its fossil fuel funding sources is structural. ExxonMobil gave Heritage $870,000 in documented grants, including $25,000 earmarked for climate programs. Heritage’s ExxonMobil-funded studies were used in reports claiming climate regulations would “inflict severe and disproportionate economic burdens on poor families.” Koch network contributions total $6.1 million documented; the Stand Together Network (Koch’s umbrella) was identified as a contributor to Heritage in Inequality.org’s October 2024 analysis of fossil fuel philanthropy. Shell USA Company Foundation donated to Heritage and other Project 2025 advisory organizations.

Key Climate Researchers:

  • Nicolas Loris — Senior Research Fellow and Deputy Director of the Thomas A. Roe Institute. Author of the Clean Power Plan Primer, Paris analyses, GND assessment, and methane regulation oppositions. Works for Cherokee Nation Businesses’ energy advocacy arm.
  • Kevin D. Dayaratna — Chief Statistician, Center for Data Analysis. Co-authored Paris cost analysis, GND cost analysis, and papers calling the social cost of carbon negligible or negative.
  • David W. Kreutzer — Former Senior Research Fellow in Energy Economics and Climate Change. Co-authored Paris analysis and “The State of Climate Science.”
  • Ben Lieberman — Former Senior Policy Analyst, Environmental Policy. Characterized the 1990 Clean Air Act’s fuel provisions as a mistake requiring rollback.

The Policy Kill Map — Labor and Unions

Minimum Wage Opposition (40 years): Heritage has produced an unbroken stream of research opposing minimum wage increases since at least 1987. “How the Minimum Wage Destroys Jobs” (Bruce Bartlett, Backgrounder No. 564, February 19, 1987) argued “economists are virtually unanimous that it reduces employment.” James Sherk — Heritage’s primary labor researcher from 2008 through 2017 — testified before Congress in 2013 in “What Is Minimum Wage: Its History and Effects on the Economy,” arguing minimum wage increases cost jobs and that studies showing employment benefits “specifically select controls to make job losses disappear.” Heritage opposed Obama-era minimum wage proposals (2013–2014) and the $15 Fight for $15 movement continuously through 2015–2021. The federal minimum wage has not been raised since July 2009.

Union Organizing: Card Check, EFCA, PRO Act: Heritage’s opposition follows the research-to-lobbying-to-outcome pipeline. “Consequences of the Employee Free Choice Act” (Sherk, April 2009) described EFCA as “the most dramatic potential reshaping of American labor law since Taft-Hartley (1947)” and argued card check “licenses union intimidation of workers.” EFCA passed the House in 2007 but died in the Senate; reintroduced in 2009, it again failed to overcome a Senate filibuster. When the PRO Act (H.R. 842) was introduced in 2021, Heritage and Heritage Action designated it a key vote and opposed it on identical grounds. The PRO Act passed the House in March 2021 (225–206) but has been blocked in the Senate. Heritage strongly supported Janus v. AFSCME (2018), which eliminated mandatory public-sector “agency fees.”

Right-to-Work Campaigns via State Policy Network: Heritage produced primary intellectual ammunition for state right-to-work campaigns from 2010 onward through the State Policy Network (SPN) — a federation of approximately 66 state-based think tanks co-founded at Heritage’s offices in the 1980s. “Right to Work Increases Jobs and Choices” (Sherk, 2011) was directly cited in New Hampshire and Indiana right-to-work campaigns; Indiana passed right-to-work in 2012. “Unelected Unions: Why Workers Should Be Allowed to Choose Their Representatives” (Sherk, 2012) was cited in Michigan legislative hearings; Michigan passed right-to-work in December 2012. Wisconsin’s 2011 Act 10, which stripped collective bargaining rights from state workers, was developed with Heritage input. The Lynde and Harry Bradley Foundation — whose family fortune came from Allen-Bradley Company (known for bitter labor conflicts) — gave Heritage approximately $7.9 million from 1998 to 2018, explicitly targeting its anti-union research capacity.

OSHA, Davis-Bacon, and Overtime: Heritage characterized workplace safety regulations as economically harmful. On Davis-Bacon, Heritage called for repeal of the 1931 prevailing wage law, arguing in “Davis-Bacon Flaws Hurt Virginia’s Workers” (Sherk and Tyrrell, 2008) that Department of Labor wage determination methodology is “scientifically unsound.” Heritage’s Mandate for Leadership guidance contributed to Davis-Bacon weakening under Reagan. On overtime, Heritage’s “Salaried Overtime Requirements” (Sherk, 2015) argued Obama’s proposed overtime rule would cause employers to cut base salaries; a federal court invalidated the rule in August 2017.

Labor Policy Summary Table:

Vote/BillHeritage PositionYearOutcome
Employee Free Choice Act (Card Check)OPPOSE2007, 2009Died in Senate
PRO Act (H.R. 842)OPPOSE (Key Vote)2021Passed House; blocked in Senate
Raise the Wage Act ($15 federal minimum)OPPOSE2019, 2021Failed in Senate
OSHA Vaccine Mandate ETSOPPOSE2021Struck down by SCOTUS (Jan. 2022)
Janus v. AFSCME (agency fees)SUPPORT2018Supreme Court ruled 5–4 for Janus

The Policy Kill Map — Tax Policy

Reagan Revolution (1981–1986): Heritage’s 1981 Mandate for Leadership called explicitly for “an across-the-board reduction in marginal personal income tax rates in each bracket of about 10 percent in 1981, with similar rate reductions in 1982 and 1983.” Reagan’s 1981 Economic Recovery Tax Act enacted a 25% across-the-board marginal rate cut, reducing the top rate from 70% to 50%. Critically, the Reagan administration appointed Heritage’s Norman Ture — who wrote the Mandate’s tax policy chapter — as Undersecretary of the Treasury for Tax and Economic Affairs. Ture’s supply-side framework governed the administration’s tax policy apparatus.

Bush Tax Cuts (2001–2003): Heritage’s Center for Data Analysis published “The Economic Impact of President Bush’s Tax Relief Plan” (William W. Beach and Rea S. Hederman Jr., CDA Report CDA01-02, April 2001) projecting that Bush’s 2001 tax cuts would grow GDP by $246 billion above CBO baseline by FY2011, create over 1.6 million new jobs, increase average family disposable income by $4,544, and — in Heritage’s most specific prediction — effectively pay off the federal debt by FY2010. The federal debt in FY2010 was approximately $13.5 trillion. Heritage produced similar dynamic analysis for the 2003 Bush tax cuts, estimating they would cost only $274 billion dynamically versus $638 billion statically — a 57% reduction in apparent cost.

Trump TCJA (2017): Heritage was among the most prominent institutional architects. Heritage hosted President Trump, Speaker Ryan, and Ways and Means Chairman Brady during TCJA’s legislative development. Heritage’s analysis projected the TCJA would grow the economy 2.6–2.8% larger in the long run, translating to roughly $4,000–$4,400 per household. “Analysis of the 2017 Tax Cuts and Jobs Act” (Heritage, December 19, 2017) called the corporate rate reduction to 21% “the most pro-growth component” and praised full expensing as the key growth driver. Heritage notably criticized the Senate for retaining “special-interest subsidies” including EV and wind energy credits and lamented that the estate tax was not fully repealed.

Opposition to Progressive Taxation: Heritage’s opposition is comprehensive. On the estate tax: “It’s Time to Fully Repeal the Unjust and Immoral Death Tax” (December 2017). On the wealth tax: “Democrats’ Proposed Wealth Tax Spells Doom for Entrepreneurs and Economic Growth” (August 2023). Heritage opposes any corporate tax increase, arguing the burden falls primarily on workers through lower wages. Heritage’s CDA has never found a tax cut harmful and has never been subjected to peer review.

The Policy Kill Map — Safety Net

Social Security Privatization: Heritage has advocated full or partial privatization since the early 1990s. David John’s “Creating a Better Social Security System for America” (1997) proposed full privatization; “The Social Security Trust Fund Fraud” (John, 1999) called privatization “the only way.” Robert Moffit’s “A Better Legacy: Social Security Reform” (2000) urged Clinton to embrace privatization as his legacy. Heritage was central to President Bush’s 2005 initiative to allow workers to divert payroll taxes to private accounts. The initiative failed politically; Heritage attributed the failure to AARP opposition.

Privatization Beneficiaries: If Social Security payroll taxes were diverted to private investment accounts — Heritage’s preferred reform — trillions of dollars would flow annually into the private financial services industry. Social Security collects approximately $1.1 trillion in payroll taxes annually. At a 0.5% average management fee, $1 trillion in annual contributions would generate $5 billion per year in fees within a decade. The firms most positioned to benefit are Heritage’s documented donors:

Financial EntityHeritage ConnectionPrivatization Benefit
Fidelity Investments$6.3M to Heritage (2017–2022)Largest 401(k) manager in U.S.; primary beneficiary of SS private accounts
VanguardVanguard Charitable donated 2022–2023Manages ~$8 trillion AUM; index fund structure ideal for SS mandates
Charles SchwabSchwab Charitable donated 2022–2023Major retirement account custodian
BlackRockCEO advocated SS private accounts (March 2025)World’s largest asset manager ($10+ trillion AUM)
Mercer FamilyRebekah Mercer is Heritage trusteeHedge fund industry benefits; carried interest preserved in TCJA

Medicare Premium Support: Heritage has consistently advocated converting Medicare from defined-benefit to “premium support” (defined-contribution) model. Robert Moffit’s 2014 report endorsed CBO analysis showing premium support could reduce Medicare spending $15–45 billion in 2020. Moffit repeatedly cited Paul Ryan’s premium support proposals as the “single best option for comprehensive Medicare reform.”

SNAP Work Requirements: Heritage’s Robert Rector is the intellectual architect of the work-requirements approach. His 1987 book Out of the Poverty Trap provided the blueprint for 1996 welfare reform. His 2001 congressional testimony “Reforming Food Stamps to Promote Work and Reduce Poverty and Dependence” proposed expanding ABAWD work requirements to ages 18–60. The “One Big Beautiful Bill” passed by Congress in 2025 implemented expanded SNAP work requirements almost exactly matching Heritage’s proposals: adults ages 18–64 must work, volunteer, or train 80 hours per month; failure to comply for three months in a 36-month period results in benefit loss. Heritage celebrated these changes as vindicating decades of advocacy.

The Policy Kill Map — Education

School Vouchers and the Heritage-DeVos Pipeline: Heritage has been the leading institutional voice for school vouchers and education savings accounts (ESAs) for over four decades. Lindsey M. Burke, Ph.D. — Director, Center for Education Policy — wrote the education chapter (Chapter 11) of Project 2025’s Mandate for Leadership. She now serves as Deputy Chief of Staff for Policy at the Department of Education in the Trump administration. Jonathan Butcher — Acting Director of the Center for Education Policy — helped design Arizona’s education savings account program (the first in the nation) and is author of Splintered: Critical Race Theory and the Progressive War on Truth (2022).

Key Heritage education publications document a sustained 40-year campaign:

YearPublicationKey Argument
2001”The Truth About School Choice”Research shows parental choice improves outcomes for low-income children
2016”The Education Debit Card II”ESAs give parents market-based freedom
2020”Correcting Carter’s Mistake”Strip DOE of cabinet status as step toward abolition
2020”The Education Lesson from COVID-19”Pandemic demonstrated need for universal choice
2022The Critical Classroom (Burke & Butcher)School choice as weapon against CRT in K–12

Heritage has declared major school choice victories across Arizona, Indiana, Florida, and Ohio, with state ESA expansions following Heritage policy blueprints.

Opposition to Teachers’ Unions: Heritage consistently frames teachers’ unions as political machines harming children. “Creating a Crisis: Teachers Unions Stifle Education Reform” (2010) documented that the NEA spent more than $71 million on politics and lobbying in the 2008 election cycle — more than ExxonMobil, Microsoft, Walmart, and the AFL-CIO combined. Heritage cited NEA polls showing 50–55% of members identify as more conservative than liberal, yet 91% of NEA campaign contributions go to Democrats, as evidence that union leadership is disconnected from membership. Heritage praised Wisconsin’s 2011 Act 10 as protecting children from “union special interests.”

Student Debt Cancellation: Heritage co-wrote the legal theory that the Supreme Court ultimately adopted in Biden v. Nebraska (2023). Lindsey Burke and Reed Rubinstein co-authored a Heritage analysis in August 2022 arguing the HEROES Act did not authorize mass student loan cancellation. The Supreme Court agreed, citing the “major questions doctrine” — doctrinal framework Heritage had been promoting through its litigation network. Heritage Action drove more than 10,000 public comments opposing Biden’s 2024 SAVE Plan, representing over one-third of all comments submitted to the Federal Register. Burke’s framing — “the truck driver in Des Moines, the waitress in Atlanta, and the service member in San Diego did not take out the loan for a master’s degree in gender studies” — became one of the defining populist attacks on cancellation.

Department of Education Elimination: Heritage’s 40-year campaign to eliminate the Department of Education has reached its most advanced stage. Heritage’s 1981 Mandate called for closing the DOE and repealing the Elementary and Secondary Education Act. Project 2025’s education chapter opens: “Federal education policy should be limited and, ultimately, the federal Department of Education should be eliminated.” In March 2025, Trump signed an executive order directing Education Secretary Linda McMahon to “take all necessary steps to facilitate the closure of the Department of Education.” By early 2026, nearly one-third of Project 2025’s 50+ higher education recommendations had been fully or partially executed.

DeVos Funding: The Richard and Helen DeVos Foundation gave Heritage $1,000,000 in 2013 alone, per Conservative Transparency records. The Dick and Betsy DeVos Family Foundation gave an additional $1.28 million from 2000–2014. The Bradley Foundation was “crucial to the voucher coalition” in Wisconsin’s pioneering school choice fights, funding $500,000 to Landmark Legal Foundation for voucher litigation, $1.5 million to PAVE in 1992, and $20 million to PAVE in 2001 to expand private school capacity.

The Antitrust Contradiction

Heritage’s position on technology antitrust represents its most publicly visible internal contradiction. In August 2021, Heritage published “Five Conservative Principles to Apply Against Weaponized Antitrust,” arguing conservatives should “reject central planning, defend the consumer welfare standard,” and that using antitrust against Big Tech would “give the Left its potentially most dangerous weapon to reshape the economy.” Six months later, in February 2022, Heritage published “Combating Big Tech’s Totalitarianism: A Road Map” (Kara Frederick), calling for aggressive antitrust investigations against Google, Amazon, Apple, Meta, and Microsoft, banning self-preferencing, and explicitly recommending that Google should not bundle its operating system, app store, and search app. Heritage President Kevin Roberts declared in February 2022: “Big Tech is an enemy of the American people.”

The libertarian Cato Institute reviewed Heritage’s 2022 road map and concluded: “What this antitrust agenda amounts to is an attempt to use and expand laws and federal agency powers to achieve outcomes they were not designed for… The agenda starts from the political ambition of browbeating these companies into changing their content policies.” The contradiction is explained by Heritage’s actual governing principle: not free markets or consumer welfare standards, but the financial interests of its donor base and political interests of the conservative movement.


Heritage Action for America

Heritage Action for America (EIN: 27-2244700) is Heritage’s 501(c)(4) advocacy and lobbying arm, founded April 2010. It translates Heritage policy research into legislative scorecards that create primary-election pressure on Members of Congress and controls the Sentinel Action Fund — a Super PAC set up in 2022 that spent $13 million on voter outreach in the 2022 midterms to elect conservative House and Senate candidates.

Heritage Action’s annual contributions have grown substantially:

Fiscal YearContributions
2011$4,584,100
2015$10,830,928
2018$10,752,465
2021$17,934,049
2022$20,072,708
2023$9,185,970

(Source: ProPublica Nonprofit Explorer)

Koch’s Freedom Partners Chamber of Commerce gave $500,000 to Heritage Action in 2013. The Campaign Legal Center filed suit against Heritage Action in 2022 for spending over $1 million in the 2018 election cycle without disclosing donors, in violation of federal campaign finance disclosure laws. The FEC failed to act on the complaint for over three years.


Donation-to-Policy Timeline

DateRecipient/TargetAmountPolicy ReturnTime Gap
Jan 1981Reagan White HouseCoors/Scaife founding investment60% of Mandate for Leadership adopted as Reagan policy in Year 1<12 months
1973–1998Heritage cumulative$23M (Scaife alone)Foundation stabilization as leading conservative institutionFoundation-building phase
1998–2016Trump Campaign / GOP Primary apparatus$5.7M Koch network donations to HeritageHeritage/Federalist SCOTUS nominee list becomes Trump’s official judicial shortlist18 years of investment → 0-day adoption
1993Clinton Health Security Act oppositionHeritage coordinated researchBill dies in Senate; Republican revolution follows in 1994<12 months
2009Waxman-Markey cap-and-trade oppositionHeritage CDA projectionsHouse passes, Senate fails; Heritage’s $9.4T figure deployed in Republican messaging<12 months
2015–2016Clean Power Plan oppositionHeritage Center for Data Analysis researchEPA rule stayed by SCOTUS in Feb 2016 before implementation<12 months
2017House Ways & Means / Trump White House$18M+ Scaife funding over prior 3 decadesTax Cuts and Jobs Act: corporate rate 35%→21%, $1.9T in cuts; Koch Industries saves est. $1–1.4B annually0–6 months from policy proposal to law
2017–2018Justice Gorsuch, SCOTUS nominationHeritage Federalist Society nominee listNeil Gorsuch from Heritage SCOTUS list appointed to Supreme Court<6 months
2019–2020Executive Office of the PresidentOngoing Heritage staffing prepSchedule F EO 13957: civil service reclassification of tens of thousands of federal workers as at-will1–2 years from Heritage paper to executive order
2022–2025Trump 2025 Transition / Federal agencies$100.9M 2023 revenue; $22M staffing budgetProject 2025: 31+ officials placed including Russell Vought (OMB), Navarro, Homan; Schedule F reimplemented3 years from project launch to implementation
2024Republican National Convention$1M direct donationPlatform alignment; Heritage preferences embedded in official GOP platformImmediate
2024–2025EPA / CFPB / NLRB / Federal agencies$965K Heritage grants to P2025 advisory orgsEnvironmental deregulation package; Chevron deference eliminated (Loper Light, 2024); NLRB gutting2–3 years from Heritage paper to Supreme Court and agency action
2025OMB / Office of Personnel Management$22M Heritage 2024 staffing preparationFederal workforce restructuring; Schedule F reimplemented within 4 days of inauguration<1 year from staffing database finalization to deployment
2025SNAP policy transformationRobert Rector decades of advocacy”One Big Beautiful Bill” implements expanded work requirements matching Heritage proposals exactly40+ year policy pipeline

Money

The ROI calculation for Heritage’s major donors is not ambiguous. The Koch network invested approximately $5.7 million in Heritage over 25 years. The Tax Cuts and Jobs Act alone — a Heritage-architected policy — saves Koch Industries an estimated $1–1.4 billion annually. That’s a 170-to-1 return in the first year of implementation. The Scaife Foundation invested $30 million in Heritage over 51 years. The deregulatory outcomes across two Trump administrations — EPA rollbacks, Chevron elimination, NLRB gutting — represent economic returns to Scaife-affiliated industries that dwarf the investment by orders of magnitude. Heritage is not a charity. It is the highest-ROI political investment in the conservative donor class’s portfolio.


The Revolving Door

Heritage’s revolving door is the most extensive in conservative politics. It is not a side effect — it is the product.

Trump 1.0 (2017–2021): At least 66 Heritage employees and alumni were hired into the administration. Heritage had maintained a database of ~3,000 vetted conservatives since 2014, specifically built for this transition. Key placements included officials in the EPA (environmental deregulation), HHS (ACA sabotage), and DOJ (immigration enforcement).

Between administrations (2021–2025): Heritage functioned as a holding pen for Trump-aligned officials. Rehires included:

  • Ken Cuccinelli (former Deputy DHS Secretary → Heritage senior fellow)
  • Mark Morgan (former Acting CBP Commissioner → Heritage visiting fellow)
  • Chad Wolf (former DHS Acting Secretary → Heritage fellow)
  • Dustin Carmack (former Chief of Staff to DNI → Heritage research fellow)

Trump 2.0 (2025–present): At least 31 individuals with documented Project 2025 connections placed in Trump’s second administration:

Heritage RoleIndividualTrump Administration Role
Project 2025 Ch. 2 author; CRA PresidentRussell VoughtOMB Director; Acting CFPB Director
Education Center DirectorLindsey BurkeDeputy Chief of Staff for Policy, Dept. of Education
Visiting Fellow (DHS Ch. author)Ken CuccinelliSenior DHS official
Tech Policy Center DirectorKara FrederickSenior national security communications role
Heritage senior fellow (FCC Ch. author)Brendan CarrFCC Chairman
America First Legal (DOJ Ch. author)Gene HamiltonSenior DOJ official
Transportation Senior Research FellowDiana Furchtgott-RothSenior DOT official
Heritage economistStephen MoorePresidential economic adviser
Heritage senior fellowHans von SpakovskyFEC advisory role

Project 2025 staff origin: 54% of the 267 Mandate for Leadership contributors previously worked in Trump’s first administration, campaign, or transition — making Project 2025 less a policy document and more a second-term to-do list written by the people who wanted to finish what they started. 25 of the 30 Mandate for Leadership chapter authors had prior Trump administration experience.

The Academy as pipeline: Heritage’s Presidential Administration Academy — the training arm of Project 2025 — processed thousands of applicants for federal positions. This is not informal networking. It is a credentialing system for ideologically vetted government staff.


What Their Funders Got

The measurable policy outcomes attributable to Heritage’s policy pipeline, cross-referenced with donor interests:

Koch Industries (oil, gas, chemicals, manufacturing):

  • Corporate rate cut from 35% to 21% (TCJA, 2017): est. $1–1.4B annual savings
  • Chevron deference eliminated (Loper Light Enterprises v. Raimondo, 2024): removes regulatory agencies’ ability to interpret environmental and safety rules
  • EPA deregulation across two administrations: weakens Clean Air Act enforcement, climate regulations
  • NLRB gutting: undermines union organizing in Koch-owned facilities
  • Minimum wage stagnation for 15+ years

Scaife Foundations (oil fortune, Mellon banking):

  • Financial deregulation advocacy: consistent Heritage output for 40+ years
  • Estate tax threshold increases (TCJA): directly benefits multi-generational wealth preservation
  • Anti-labor regulatory rollbacks
  • Climate denial infrastructure: $30M+ sustained over 51 years

Bradley Foundation (industrial manufacturing, anti-union focus):

  • Education privatization: Heritage advocated school vouchers since 1970s; DeVos-era Department of Education implemented them
  • Right-to-work advocacy: Heritage produced research framing union dues as coercion; 22+ states passed RTW legislation using Heritage talking points
  • $7.9M targeting anti-union research capacity; Bradley’s 2024 annual giving of $14.5M to local and state conservative groups amplified Heritage RTW research

Coors Family (beer, real estate):

  • Federal land deregulation: consistent Heritage policy output
  • Liquor and alcohol industry regulatory rollbacks
  • Union busting: Heritage minimum wage and right-to-work research countered Coors’ labor opposition

DeVos Family (education privatization, multi-level marketing):

  • Department of Education restructuring: Heritage had recommended dismantling the department for decades; now being executed
  • For-profit education deregulation
  • Amway business model protection: Heritage opposition to employee classification rules, worker protections, and FTC oversight of MLM companies

Financial Services (Fidelity, Vanguard, Schwab, BlackRock):

  • Social Security privatization: if implemented, would divert $1.1 trillion annually in payroll taxes to private investment accounts, generating $5B+ per year in management fees
  • $6.3M to Heritage from Fidelity (2017–2022) alone; $18M+ from all donor-advised funds since 2020

Pharmaceutical Companies (PhRMA, Pfizer, J&J, GSK, Novartis):

  • Drug price control opposition: PhRMA gave $212,500 to Heritage + $37,500 to Heritage Action while Heritage opposed drug price negotiations
  • Medicare For All defeat: $24.7–32T opposition projections deployed in congressional messaging
  • FDA deregulation: reduced oversight of drug approval and pricing

ExxonMobil ($870K documented):

  • Kyoto Protocol opposition: $23M Scaife + $870K ExxonMobil funding opposed international climate agreement
  • Paris withdrawal: Heritage projections cited by Trump for 2017 withdrawal announcement
  • Endangerment Finding defense: Heritage defended ExxonMobil against state attorney general climate investigations

Lockheed Martin ($341K documented):

  • F-22 Raptor program: Heritage published “flurry of reports” supporting program after Pentagon recommended cutting it; ~$13B program saved through Heritage advocacy coordinated with monthly executive meetings

Money

The combined policy return to Heritage’s major donors across two Trump administrations exceeds $1 trillion in regulatory relief, tax savings, and weakened enforcement capacity — against a total investment in Heritage of approximately $50–75 million over 25+ years. Scaife alone invested $30M over 51 years and received returns in the hundreds of billions through deregulation, tax cuts, and prevented labor/environmental protections. This is the foundational argument for why wealthy donors fund think tanks: the leverage ratio between investment and political return is unmatched by direct lobbying or campaign contributions.


Class Analysis

Heritage Foundation is the institutional manifestation of a core truth about American policy formation: ideas have funders, and funders have interests.

The “independent research” framing is load-bearing fiction. Without it, Heritage is a lobbying organization. With it, Heritage is a tax-exempt educational institution whose work happens to recommend, in every instance, policies that benefit its donors. The 501(c)(3) status saves Heritage’s donors approximately $30–40 million annually in foregone taxes (based on Heritage’s revenue and estimated marginal donor tax rates) — meaning the government subsidizes the factory that produces policy designed to further enrich the donors funding it.

The analytical patterns present in Heritage’s operation:

Idea Laundering: Donors fund research → research supports donor’s preferred policy → politician cites “independent research” → policy serves donors. Heritage is the mechanism by which private interests become public policy with academic citations attached.

Regulatory Capture Pipeline: The Presidential Administration Academy trains future regulators who then implement Heritage’s (i.e., the donors’) preferred regulatory framework. This is not a bug in the system — it is the system. Heritage trains the people who will dismantle the regulations that constrain its donors.

Model Legislation Pipeline: Schedule F began as a Heritage policy paper. It became a White House executive order. It was reversed. It was reimplemented within 4 days of Trump’s second inauguration. The pipeline from Heritage paper to federal law is well-worn and moves fast.

Bipartisan Credibility Shield: Heritage cultivates relationships with nominal Democrats and funds some outreach to Black and Latino communities specifically to maintain the “nonpartisan” branding that protects its tax status. The funding and the policy output remain entirely aligned with the donor class’s interests.

The Individual Mandate Reversal: Heritage invented the individual health insurance mandate in 1989. Heritage immediately opposed it when Democrats adopted it in the ACA. Heritage filed legal briefs arguing its own creation was unconstitutional. This is not intellectual inconsistency. It is the behavior of an organization whose policy positions are determined not by principles but by the financial interests of its donor base and the political interests of the conservative movement.

Donor-Class Override: Policy outcomes that directly contradict constituency interest but serve donors. Koch Industries saves $1–1.4B annually from tax cuts funded by their $5.7M Heritage investment. Financial services firms position themselves to capture $5B+ annually if Social Security is privatized. Pharmaceutical companies avoid price controls that would reduce profits. This pattern repeats across every Heritage policy domain.

Predetermined Conclusions: Heritage’s Center for Data Analysis has never produced an analysis finding that a tax cut is harmful and has never been subjected to peer review. Heritage’s Waxman-Markey projection was 54 times the CBO’s per-family cost estimate. Heritage’s Clean Power Plan projection came with a model that literally crashed. Heritage’s Paris analysis argued CO₂ emissions are a net economic benefit. The gap between Heritage’s outputs and independent analysis is not methodological — it is structural.

The December 2025 staff exodus — 12+ senior Heritage employees leaving over antisemitism concerns to join Mike Pence’s new organization — illuminates a secondary dynamic: Heritage’s power is not located in any individual. The personnel database, the policy papers, the donor relationships, and the Mandate for Leadership framework persist independently of staff. The institution is more durable than any administration, any president, or any staff member. That durability is the point.


Sources


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