Federal investigators in Sacramento are examining the nonprofit network built by Jennifer Siebel Newsom, California's self-styled "First Partner", and the financial arrangements connecting her tax-exempt organizations to her own for-profit production company. Legal experts who reviewed the structure say it raises serious questions about IRS compliance, partisan political activity, and whether charitable dollars improperly benefited insiders.
Gov. Gavin Newsom has framed the investigation as political retaliation by the Trump administration. But that narrative has a problem: the probe originated during the Biden presidency, triggered not by a White House directive but by whistleblower complaints submitted to the U.S. Attorney's Office in Sacramento.
The scope of the investigation, the dollar amounts involved, and the overlapping relationships between the Newsoms' political operation and their charitable apparatus paint a picture that demands more than a wave-of-the-hand dismissal. A detailed investigation by Susan Crabtree of RealClearPolitics, published by the New York Post, lays out the financial architecture, and it is worth following the money carefully.
At the center of the arrangement sit three entities. The Representation Project is a 501(c)(3) nonprofit that produces documentary films and sells educational screening packages to schools for nearly $300 apiece. Girls Club Entertainment is a for-profit production company also operated by Siebel Newsom. And the California Partners Project is a second nonprofit focused on gender equity initiatives.
IRS filings show that Girls Club Entertainment received approximately $3.7 million from the Representation Project between 2012 and 2023, roughly $300,000 a year. The arrangement works like this: Girls Club produces documentaries, then licenses them back to the nonprofit, which markets them to schools. Siebel Newsom serves as paid CEO of the Representation Project while simultaneously running the for-profit company that collects licensing fees from it.
The Washington Free Beacon reported that since 2020, Siebel Newsom has received approximately $760,000 in salary plus $773,000 paid to her private LLC from the Representation Project, potentially $1.5 million in personal income flowing from a charity she controls.
Chuck Walker, a retired IRS agent who specialized in tax-exempt organization compliance, explained the risk in plain terms. He told the California Post he could not comment specifically on the Siebel Newsom organizations, but laid out the general rule:
"If there is any advantage, fruit, or gain to an insider, which could be an officer, director, founder, substantial contributors, key person, basically somebody who controls it, there is an excise tax of 25% that can be imposed on that excess benefit to the individual."
That is not a trivial regulatory footnote. It is the IRS mechanism designed to prevent exactly the kind of self-dealing arrangement that critics say the Newsom nonprofit structure resembles.
The Representation Project claims its film curricula have reached over two million students in roughly 5,000 schools across all 50 states. The organization's website declares its mission is "bending the long arc of history toward intersectional gender justice." But the curriculum materials go well beyond gender discussion, and into territory that California political law attorney Derek Ross says should concern the IRS.
One curriculum guide instructs students to "Register to vote, if you're not already registered. Then vote for candidates who show empathy through their support care policies (a living wage, equal pay, paid family leave, universal healthcare, well-funded education, progressive taxation, policies that value caregiving/homemaking, etc.)" It then urges students to "work on campaigns to register others to vote for candidates who support a care economy."
Ross did not hold back about what that language means in practice:
"Any reasonable reader will understand candidates who support those policies means Democrats."
He added that a 501(c)(3) "cannot condition registration outreach on the registrant's policy views," warning that to the IRS, "that's potentially targeted partisan registration activity, which is prohibited."
The curriculum also includes the "Genderbread Person" graphic promoting nonbinary gender ideology and a "Privilege Walk" exercise covering race, gender, sexual orientation, and socioeconomic status. These materials are being sold to schools, including middle schools, as educational content produced by a tax-exempt charity.
Ross flagged the broader structural concern as well: "If 501(c)(3) funds were used to draft and/or distribute the curriculum language, it raises significant concerns under IRS rules governing charitable organizations."
There is precedent for the IRS taking action in cases like this. In the landmark 1989 American Campaign Academy case, the IRS successfully denied tax-exempt status after determining the organization primarily benefited one political party rather than the public. The parallels are hard to miss.
Research by OpenTheBooks.com found that Gavin Newsom appears five times in "The Great American Lie," one of the Representation Project's documentaries, delivering political messages. In one appearance, the governor says: "We're not bystanders in this world, we have the ability to step up and solve big problems." He also appears in "Miss Representation: Rise Up," which debuted recently.
Newsom's spokeswoman, Tara Gallegos, told reporters that "The Governor's participation (which was filmed before he even took office) was in his personal capacity" and that "The material you are referencing is not connected in any official capacity to the state." She did not directly answer whether the Newsoms sought legal advice regarding the governor's appearances in the films.
The federal probe has expanded beyond the nonprofit question into the broader financial ecosystem surrounding the Newsom family. Grand jury subpoenas have been issued, and the investigation reportedly has multiple arms.
Then there are the behested payments, donations solicited by elected officials and directed to specific organizations. Public records show California politicians directed $555.9 million in behested payments over the past 15 years. Newsom accounted for $347.2 million of that total, more than 62 percent of the statewide figure.
The California Partners Project alone received at least $4.3 million in behested payments. The California Fair Political Practices Commission fined Newsom $31,500 on June 18 for failing to timely disclose certain behested payments, a legal requirement that exists precisely because of the corruption risks these arrangements create.
Gallegos defended the practice, saying "Behested payments are a longstanding, legal, and transparent practice used by officials of both parties to support charitable and government initiatives, with public disclosure required under the law." She added: "The existence of publicly reported behested payments is evidence of transparency, not wrongdoing."
Transparency, however, requires timely disclosure, which is exactly what the FPPC found Newsom failed to provide.
The donor relationships surrounding Siebel Newsom's nonprofits raise their own questions. PG&E, the utility convicted on six criminal counts following the fatal San Bruno gas pipeline explosion and later found criminally liable for the wildfire that killed 84 people in Paradise, donated at least $360,000 to the Representation Project. In return, PG&E received a board seat and a producer credit on one of the films. The company also contributed $350,000 to support Newsom's Proposition 1, a $6.4 billion mental health and homeless housing bond approved by voters in 2024.
The Newsoms reportedly stopped accepting PG&E donations after the Paradise fire. But the earlier arrangement, a criminally convicted utility buying its way onto a nonprofit board while the governor's wife runs the organization, speaks for itself.
Just the News reported that the Federated Indians of Graton Rancheria donated $500,000 to Siebel Newsom's California Partners Project in April 2024, just months before Newsom intervened to block a rival tribe's casino project. The tribe donated again in April 2025, a month before Newsom sued to block the same competing casino. Ethics watchdog Michael Chamberlain, director of Protect the Public's Trust, called the arrangement "very troubling and likely warrants further investigation by authorities."
Pritzker family members contributed nearly $650,000 to the California Partners Project. In 2024, Newsom purchased a $9.1 million home from Daniel Pritzker, a Pritzker family heir. The board of the California Partners Project itself includes Tom Willis, a partner at the law firm Olson Remcho that regularly represents Newsom before the FPPC; Brian Brokaw, a longtime Newsom adviser; and Joanna Rees, whom Newsom appointed to chair the California Workforce Development Board in 2025.
The celebrity supporters, Reese Witherspoon, Melinda French Gates, Hillary Clinton, Nancy Pelosi, provide the Representation Project with cultural credibility. The Getty family, described as longtime benefactors of Newsom's business ventures and political career, remain closely connected; Aileen Getty serves as executive producer of the nonprofit's newest documentary.
Federal legal troubles have already reached Newsom's inner circle, with his former chief of staff pleading guilty in a federal campaign fraud scheme, a fact that makes the broader pattern harder to dismiss as coincidence.
Newsom has leaned hard into the claim that the investigation is politically motivated. He declared publicly that Trump "directed his Department of Justice to investigate me" and said that "to get me, he's coming after my wife, Jen." Siebel Newsom echoed the framing, saying "There are clearly no boundaries to what Donald Trump will do to get his way or to challenge those who get in his way."
But the timeline undermines the narrative. The probe was opened in 2022, under President Biden's Justice Department, and was sparked by whistleblower complaints, not a political directive. Journalist Adam Housley noted bluntly: "They've been under federal investigation since the Biden admin. This isn't new."
Newsom himself has offered shifting explanations. He told reporters: "They have not found a crime, they are simply trying to find one. He isn't coming after me because of mean tweets, but because I am considering running for President."
That line is revealing. A governor under federal investigation pivots from claiming victimhood to floating a presidential campaign, as if the probe is a credential rather than a concern.
Meanwhile, the corruption questions surrounding Siebel Newsom's nonprofit network continue to multiply. The Representation Project's partnership in 2025 with the Positive Coaching Alliance, an organization that has opposed bans preventing transgender athletes from competing in girls' high school sports, adds another layer of contradiction for an organization that claims to champion women and girls.
Significant questions remain open. Which federal agencies are conducting the investigation, the FBI, IRS Criminal Investigation, or both? Has Siebel Newsom received a subpoena or been notified of her status as a subject or target? Did the Representation Project or California Partners Project receive any state government contracts or grants? And what are the "other undisclosed activities" that investigators are reportedly examining?
The pattern of questionable financial relationships surrounding the Newsom family is not new. What is new is that federal investigators are now pulling the threads, and the threads lead in many directions.
Newsom wants voters to see a political hit job. But the IRS filings, the behested payment records, the curriculum materials, the donor-to-policy timelines, and the growing list of controversies surrounding the First Partner's public conduct tell a different story, one about a nonprofit empire that looks less like charity and more like a family business with a tax exemption.
When the powerful claim they are victims, the rest of us should check the books. The feds apparently already are.
