A whistleblower has revealed that a covert tax-exempt fund of the Mormon church has a value of $100 billion, and does not meet the requirements to maintain its tax-exempt status.
Mormon members in good standing are required to pay a “tithing” of 10% of their income to the church. (Failure to pay results in being banned from certain church services including Mormon weddings, as well as facing social stigma. Members are often required to produce financial documents to prove that they are paying sufficiently.) The excess of these tithes over the church’s operating expenses, estimated at $1-2 billion per year, has since 1997 entered the Ensign Peak Advisors, Inc. (EPA) fund, where it has accrued 7-10% return on investments to accumulate over $100 billion by 2019.
The EPA fund is a supporting organization of the Corporation of the President of Church of Jesus Christ of Latter-Day Saints (i.e., the Mormon church, organized as a corporate sole owned by the current Mormon prophet), and claims a 501c3 exemption from taxes as it purports to spend its resources on religious, educational, charitable, or other exempt purposes. Note that “investing” and “saving” are not considered exempt purposes.
However, since 1997 EPA has spent absolutely none of its money on exempt purposes: in fact it has only made outlays twice. In 2009, it spent $600 million to bail out a for-profit insurace company owned by the Mormon church, and from 2010 - 2014 it collectively spent $1.4 billion to cover cost over-runs of the construction of the for-profit City Creek Mall, also owned by the Mormon church. In particular, the $1.4 billion came directly from tithing cash that had not yet been invested, despite claims from the church that no tithing money had contributed to City Creek Mall.
More specifically, the IRS requires private foundations to spend a minimum of 5% (follow links to “distributable amount” and “minimum investment return”) of its assets on charitable purposes each year, or face penalties of 30-100% of the amount that should have been spent. EPA does not meet this requirement. (There are limited exceptions for setting aside funds for up to 60 months for large projects, but it has been 22 years since EPA’s founding, and such projects must be approved by the IRS in advance.)
EPA employees are told (among other reasons) that the purpose of the EPA money is to save for armageddon or the second coming. These are not tax-exempt purposes, and one hardly expects money to be especially relevant at such a time anyhow.
What makes EPA “covert”? It was founded in 1997 one month after a Times magazine cover story “Mormons, Inc.” about the extensive business holdings of the Mormon church, for the purpose of concealing these holdings in the future. It has a bare-bones staff of 75 people organized into teams whose data is “siloed” from each other; only 4 EPA employees are authorized to know the complete financial information. EPA has no sign in its lobby. All EPA employees are required to be tithe payers who hold “temple recommends” (i.e., obedient Mormons): until 2017, the head of EPA “would go desk-to-desk requiring employees to show the temple recommend that they were required to keep current. Now, temple-recommend checks are conducted electronically, automatically, and periodically. In addition, the COP implemented in 2019 a means for local clergy to electronically surveil and report to church headquarters the weekly church attendance and temple worthiness of church employees who attend that specific congregation.”.
BYU owns a small amount of funds managed by EPA, and until 2015 auditors of BYU accepted EPA’s refusal to allow any examination of EPA financials. At that point pressure from auditors eventually led EPA to form a separate account for assets owned by BYU (and other arms of the church) so that auditors can examine the limited account without getting access to full EPA financials. Similarly, when financial partners request financial information from EPA to comply with the Patriot Act’s disclosure requirements, EPA simply gives a letter saying that “Ensign Peak does not distribute financial statements” but assets are above “$5.0 billion”.
In 2017, EPA ended a financial relationship with a bond broker when it was realized that they were on the board of Open Stories Foundation, which had supported the Mormon Stories Podcast, which was run by a prominent exmormon John Dehlin. In 2018, one day after MormonLeaks had revealed the existence of 13 LLCs worth billions of dollars and secretly owned by the Mormon church (and which we now know were owned specifically by EPA), EPA held an internal meeting to discuss the formation of new holding companies to better conceal their ownership; it was decided that this would be too obvious if done immediately, and would be better done over several years.
The Mormon church has a very long history of fraud, starting with its founder Joseph Smith’s treasure hunting. The whistleblower recounts an early such incident, when Smith illegally started a bank and illegally printed money, which bore the mark “THE KIRTLAND SAFETY SOCIETY ANTIBANKING CO”, with “anti-” and “-ing co” written in very tiny font.
EPA continues this tradition. It submits essentially no financial information to the IRS and is thus effectively immune to oversight. It does, however, submit a form 990T to the IRS, which requires the disclosure of “Book value of all assets at end of year”. In 2007, 2008, and 2010-2015, EPA has each year claimed “$1,000,000.” as a book value, with some years prepending the word “over”; most recently in 2017, EPA has just left the field blank.
It is possible, however, that the EPA financials contain something much more serious – or rather, don’t contain. The whistleblower discovered that EPA has a deliberate policy of deleting from its records unpaid accounts receivable: that is, when investing in another entity, if the investment doesn’t come back, then to delete the missing investment from its assets. This allows payments to other entities to be concealed as loans which never get repaid. However the whistleblower has no knowledge of such a payment taking place.
If the whistleblower’s understanding of the church’s motives are correct, then the Mormon church does not even want the money (or so much, anyhow): it is a curse.
Certainly all this money is not benefiting the church: EPA does not spend its money, only accumulates it indefinitely. What the church (allegedly) wants is not money, but secrecy. By registering as a 501c3 organization and concealing its holdings behind fraudulent tax documents and layers of LLCs, the church is able to hide how much money it has. If EPA followed the law by paying taxes, or by charitably disbursing funds in accordance with its tax-exempt status, it would be required to report how much money it has and spends; furthermore, it would be difficult to charitably spend tens of billions of dollars a year without visibly partnering with major international secular organizations.
By concealing the value of its assets, the church is able to represent to its members that it is much poorer than it is and thus credibly demand crippling tithes and volunteer labor:
“If paying tithing means that you can’t pay for water or electricity, pay tithing. If paying tithing means that you can’t pay your rent, pay tithing. Even if paying tithing means that you don’t have enough money to feed your family, pay tithing.” - official Mormon church newsletter, 2012
The demands made on its membership are a means of control. It is therefore critical to the church that the membership do not become aware that their tithe is unnecessary. Not only does tithing exceed operating expenses by more than $1 billion per year, it is estimated that the returns on investment from EPA alone exceeds tithing: thus the Mormon church could cease collecting tithing and survive its current operating expenses in perpetuity without even drawing down on the balance of EPA.
Mormons are told to donate exclusively to the church to avoid the operating overhead of secular charitable organizations. Were the church to perform charitable work in partnership with other organizations (and how else could it spend nearly $10 billion a year?), this lie would be revealed.
When combined with the real estate holdings that EPA manages (which includes 2% of the land area of Florida, making the Mormon church the largest land owner in Florida), EPA has approximately $124 billion in funds: only 10 countries have soverign wealth funds larger than this. Would Mormons still feel beholden to the church if this were known?
(Note that EPA does not own all Mormon church assets, but only owns highly liquid assets – in fact it holds $7 billion in cash, and estimates it could liquidate 85% (!) of its holdings within 3 months. The church has many other subsideries, both non-profit and for-profit, which hold their own extensive reserve funds, together with extensive non-liquid holdings in Mormon temples and other physical property. Because many of these assets don’t go to market for many decades, it is difficult to value them, but crude estimates of the total valuation of the Mormon church go above $200 billion.)
There are a number of ways that restitution, if it takes place, could be calculated: the whistleblower presents calculations for several such methods. What I found interesting was the calculation of the EPA’s value had it maintained the minimum annual disbursement of 5% of assets required to maintain tax-exempt status. In this scenario, it would be worth an estimated $67 billion less than it is today. (Note that such a scenario imposes no practical burden on the Mormon church: it did not use any of this $67 billion, had no plans to use it in the future, and would still be left with a $33 billion reserve that it doesn’t need.) This difference represents what it is has collectively cost the US to allow EPA to get away with failing to follow the tax-exemption requirements. Between 327 million US residents, each US resident has effectively subsidized (on average) $202 into growing EPA’s funds.
For one US resident, EPA’s fraud may be worth quite a bit more. Whistleblowers who reveal to the IRS the fraudulent omission of tax payments receive 15% (or even up to 30%) of the amount that the IRS recovers. Under reasonable estimates of the amount of taxes that EPA owes to the IRS, such a payment could make the whistleblower a billionaire – with enough money leftover to make charitable donations exceeding the Mormon church’s entire charitable work for the last 22 years.
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