In August 2016, as the general election approached, then-candidate Donald Trump was pressed on his failure to release his tax returns in an interview with The Washington Post. He reiterated his by-then standard line that his returns were under audit and that he therefore was being advised not to release them, an argument that’s been parsed in hundreds of different ways since he first made it.
But he also argued that he’d already presented much more information than his returns would offer anyway by releasing federally mandated financial disclosure documents.
“Those give you much more detail than tax returns, okay?” Trump claimed. “Tax returns give you nothing. Tax returns give you no information.”
Last week, Trump released the latest iteration of his financial disclosure, documents that do indeed provide at least some overview of his business interests. The document is broken out into several sections. One details his employment assets and income, which, for Trump, includes income from his resorts, rent and sales income from his real estate, royalties from books and income he receives from his past appearances in movies and on television. Another section outlines the first lady’s income. Another provides other assets, including various investments. The document also lists his liabilities, including multimillion-dollar loans he’s received from various financial institutions, including Deutsche Bank.
Perhaps the most interesting section, though, is an appendix in which all the corporate entities in which Trump has a stake are identified. It’s a mishmash of various oddly named limited-liability companies and corporations like THC Rio Managing Member Corp or HWA 555 Owners LLC. That section looks like this:
There are hundreds of similar entities, most of which indicate ownership that includes other named entities. On the example above, you’ll notice that Trump AC Casino Marks LLC is owned in part by Trump AC Casino Marks Member Corp.
As it turns out, most of the entities in the document flow back up to another entity listed in the document. That makes sense; after all, we’re talking about Trump’s business empire. Most of it flows up eventually to the Donald J. Trump Revocable Trust, the entity created by the president after he won the presidency to remove him from the Trump Organization structure.
We indexed each of the named organizations in the Trump disclosure and noted the connections between them. The result looks like this, with each circle representing a business entity, scaled to the amount of income reported in Trump’s 2018 document.
That diagram is broken into a few sections.
At the top, anchored by the Trump trust, are a number of entities like the Trump Corporation or Trump Plaza which are directly owned by the trust. There are also a number of entities which are jointly owned by entities owned by the trust and by a group referred to as Trump Family Members. This includes All County Building Supply and Maintenance Corp, made famous by New York Times reporting showing how the company was used by Trump’s father to pass income to Trump and his siblings without having it taxed.
In the middle are two large entities that together own much of the rest of the universe of businesses. Those are DJT Holdings LLC and DJT Holdings Managing Member LLC.
At the bottom are a cluster of entities which are mostly used to manage various trademarks. There, again, there are two anchor entities: DTTM Operations LLC and DTTM Operations Managing Member Corp.
You’ll notice the similarity of those structures. In most cases, entities listed in the disclosure document have two owners as in the pattern shown above: An LLC and a membership corporation. Here, for example, is how Trump’s golf course in D.C. is structured.
The course (Trump National Golf Club — Washington DC) is owned by two organizations, DJT Holdings LLC (which owns 99 percent of it) and Trump National Golf Washington DC Member Corp, which owns the other 1 percent. The member corporation, though, is identified in the documents as the “managing member.” The member corporation is owned by DJT Holdings Managing Member LLC. Both DJT Holdings LLC and DJT Holdings Managing Member LLC are owned by the trust.
So why structure things this way? Steven Goldburd, managing partner at the tax law firm of Goldburd McCone, explained in a phone call with The Post.
The golf course is structured as a partnership. One effect of structuring ownership of these entities that way, Goldburd said, is that while income from the business can flow up to the entities that own it, the business itself wouldn’t be identified by name in Trump’s tax returns.
“Income will flow up,” Goldburd said. “It’s just that the actual name you’re looking for” — like the golf course — “will not show up” in tax documents. Instead, in this case, DJT Holdings LLC and DJT Holdings Managing Member LLC will appear.
For what it’s worth, the identified “managing member” is generally the one that is responsible for filing tax returns for the corporation, Goldburd explained. “If it was a human being,” he added, “that would be the company to direct the lower tier, the actual entity, of what it’s to do. The boss.”
Mar-a-Lago offers a slightly different example.
Mar-a-Lago is still a partnership, but in this case the trust owns most of it directly. Only one one-hundredth of a percent is owned by Mar-a-Lago Club Inc, one of the club’s two partners.
There are more than 500 similar entities and relationships. The financial disclosure includes income information for 117 of them. For 47 organizations, the amount of reported income ranged from nothing to $99,999. For 43, income topped $1 million — including Trump’s best-known properties like Mar-a-Lago or his golf courses.
To illustrate the complexity of those relationships, we created an interactive tool allowing you to click on various companies and see who owns what and how. We’ve also included information about the income reported in the financial disclosure for each entity.
You’ll notice, as you explore the tool, that most of the entities listed in Trump’s document aren’t ones for which income was reported directly. On some occasions, the appendix indicates that the entity’s income was reported as part of another entity. Income from Trump Chicago Retail LLC, for example, was disclosed as part of 401 North Wabash Venture LLC. Both entities are owned by 401 Mezz Venture LLC. (You can click “DJT Holdings LLC,” then “Trump Chicago Member LLC” and then “401 Mezz Venture LLC” in the interactive to see the relationship.)
According to Goldburd, Trump actually had a point when he spoke to The Post three years ago. Because of how much of his business is structured, many of the entities included in his financial disclosure documents might not have been named in his tax returns. That doesn’t change the fact, though, that much of what Trump earns and how he earns it is still hidden from view.