Commissioner, Internal Revenue Service
1111 Constitution Ave NW #5480
Washington, DC 20224
I am writing to inform you that the Republican National Committee (“RNC”) has filed a Form 13909 Tax-Exempt Organization Complaint (copy attached) to bring to your attention misreporting in at least two of the annual filings of the Clinton Health Access Initiative (“CHAI”), EIN#: 27-1414646. CHAI, a non-profit which was spun off of the Bill, Hillary and Chelsea Clinton Foundation, formerly the William J. Clinton Presidential Foundation (“Clinton Foundation”), was formed in 2010. I request that the Internal Revenue Service (“IRS”) engage in a comprehensive audit of CHAI’s financial records to investigate the accuracy of its IRS Form 990 filings, particularly in the area of government grants.
According to published reports, CHAI has acknowledged errors in the reporting of government grants in its IRS Form 990 filings for 2012 and 2013. However, yesterday, in a report in Politico, CHAI confirmed that despite publicly admitting these errors earlier this year, it had no plans to amend its filings. As you are fully aware, IRS Form 990 is certified under penalty of perjury, and in both years, foundation Chief Financial Officer Julie Feder certified the filings.
In the Politico report, CHAI also falsely claimed that it had not previously planned to amend its 2012 and 2013 filings. But in an email from March of this year, a foundation spokeswoman told a reporter for Reuters that an “error [was] made when completing the revenue breakout section of the Form 990” and that the foundation was “working diligently to make the necessary amendments to the returns.”
CHAI’s failure to accurately report foreign government grants is not unique to its interactions with the IRS. As an organization run by former President Clinton, and on whose board former Secretary of State Hillary Clinton once sat, the Clinton Foundation was subject to an ethics arrangement while Mrs. Clinton served as Secretary of State to guard against conflicts of interest, particularly from foreign government sources. Under the arrangement, CHAI was required to submit all new or increased foreign government contributions to the Department of State for independent vetting for conflicts of interest. Yet from 2009 to 2013, CHAI never submitted a single foreign government donation to the Department of State for vetting. 
Given CHAI’s history of repeatedly failing to accurately report the amount of money it received from foreign governments and its refusal to amend its Form 990 filings, there is no way to tell whether there exists other undisclosed foreign government grants without the IRS conducting a full audit of CHAI’s financial records. I therefore urge you to conduct such an audit and compel CHAI to make the necessary amendments to its Form 990s from 2010 to 2013. The American people deserve to know whether the largest philanthropic arm of the Clinton Foundation continues to misreport the funds it receives from foreign governments, and whether this might lead to the potential for further conflicts of interest.
Chairman, Republican National Committee
Download the submitted letter here.
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