Exclusive | Jennifer Siebel Newsom’s nonprofit network faces legal questions amid federal investigation

When Gov. Gavin Newsom declared that federal investigators were targeting his wife as retaliation for his battles with the Trump administration, he offered a familiar defense: Cast the powerful as victims and hope no one looks too closely behind the curtain.

His wife, Jennifer Siebel Newsom — who uses the title “First Partner” — was described by the governor as someone who has “dedicated her life to supporting women and girls,” portraying her work as charitable and separate from his political career.

A closer look tells a more complicated story.

Legal experts who spoke to The California Post said at least one of Siebel Newsom’s nonprofits — and its financial relationship with her for-profit production company — raises significant questions about compliance with federal tax-exempt charity laws.

Federal investigators based in Sacramento are examining Siebel Newsom’s nonprofits, tax matters and other undisclosed activities.

Political activism in the classroom

Siebel Newsom oversees two nonprofits: The Representation Project, which produces documentary films and educational materials, and the California Partners Project, which focuses on gender equity initiatives.

Two of her documentaries — “Miss Representation: Rise Up” and “The Great American Lie” — feature the governor providing political commentary. Accompanying classroom materials encourage middle school, high school and college students to participate in civic and political activism.

In “The Great American Lie,” Newsom appears five times delivering political messages, according to research by OpenTheBooks.com, including: “We’re not bystanders in this world, we have the ability to step up and solve big problems, we have done that in the past, it’s just a question of prioritization, of political will.”

One accompanying curriculum asks students: “What other actions can you take at a community level to reduce inequality?”

The lesson continues: “Register to vote, if you’re not already registered. Then vote for candidates who show empathy through their support [sic] care policies (a living wage, equal pay, paid family leave, universal healthcare, well-funded education, progressive taxation, policies that value caregiving/homemaking, etc.) Also, work on campaigns to register others to vote for candidates who support a care economy.”

Derek Ross, a California political law attorney, said the language raises significant legal concerns.

“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,” Ross told The California Post.

“Any reasonable reader will understand candidates who support those policies means Democrats,” he said.

Ross said the voter registration language also raises concerns.

“A 501(c)(3) cannot condition registration outreach on the registrant’s policy views,” he said. “To the IRS, that’s potentially targeted partisan registration activity, which is prohibited.”

Newsom’s spokeswoman Tara Gallegos said the claims had ”nothing to do with our office.”

“The Governor’s participation (which was filmed before he even took office) was in his personal capacity,” she said.

Chuck Walker, a retired IRS agent who specialized in tax-exempt organization compliance, said he could not comment specifically on the Siebel Newsom organizations but said any charity encouraging support for candidates aligned with a particular political philosophy risks violating IRS rules.

“The country is very polarized, and there’s not much of a gray area,” Walker told The Post.

“When you say vote for someone who shares our values for progressive taxes, of course the conservative side would support less taxes, and on the liberal side, it’s a more progressive tax system.”

Walker said a statewide elected official appearing prominently in a spouse’s nonprofit-funded productions — combined with money flowing between nonprofit and for-profit entities – would likely attract IRS scrutiny.

He pointed to the landmark 1989 American Campaign Academy case, in which the IRS successfully denied tax-exempt status after determining the organization primarily benefited one political party rather than the public.

Those signing nonprofit tax returns certify under penalty of perjury that the organization is not engaged in prohibited political activity or providing improper private benefits, Walker said.

“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,” Walker said.

Gallegos did not directly answer whether either Jennifer or Gavin Newsom sought legal advice regarding the governor’s appearances in the films.

“The material you are referencing is not connected in any official capacity to the state,” she said.

The business model

The financial structure of Siebel Newsom’s organizations is closely connected.

Her for-profit production company Girls Club Entertainment produces the documentaries before licensing them to the nonprofit Representation Project, where she serves as paid CEO. The nonprofit then sells educational screening packages to schools nationwide for nearly $300 each.

According to Siebel Newsom, roughly 5,000 schools in all 50 states have purchased the materials.

IRS filings show Girls Club Entertainment received approximately $3.7 million from the Representation Project between 2012 and 2023 — roughly $300,000 annually.

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.

The company later received a board seat and a producer credit on one of its films.

The Newsoms stopped accepting PG&E donations after the Paradise Fire. The utility later contributed $350,000 to support Newsom’s Proposition 1 mental health ballot measure, the $6.4 billion mental health and homeless housing bond approved by voters in 2024.

A network seeded by the governor

The California Partners Project has also received at least $4.3 million in behested payments — charitable donations solicited in the name of a public official.

California law requires such payments to be publicly disclosed, though critics describe the practice as legalized pay-to-play.

The nonprofit’s board further illustrates its political connections.

Members include Tom Willis, a partner at Olson Remcho, the law firm that regularly represents Newsom, including before California’s Fair Political Practices Commission, which fined the governor $31,500 on June 18 for failing to timely disclose certain behested payments.

Other board members include Joanna Rees, whom Newsom appointed to chair the California Workforce Development Board in 2025, and Brian Brokaw, a longtime adviser to the governor.

Gallegos defended the practice.

“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 said.

“The existence of publicly reported behested payments is evidence of transparency — not wrongdoing.”

Critics argue the scale deserves greater scrutiny.

Public records show California politicians directed $555.9 million in behested payments over the past 15 years. Newsom alone accounted for $347.2 million — more than 62% of the statewide total.

The nonprofit network also overlaps with many of Newsom’s longtime political and financial allies.

Members of the Pritzker family have contributed nearly $650,000 to the California Partners Project.

In 2024, Newsom purchased a $9.1 million home from Pritzker heir Daniel Pritzker.

The Getty family – longtime benefactors of Newsom’s business ventures and political career — also remain closely connected.

Aileen Getty serves as executive producer of the Representation Project’s newest documentary.

Actress Reese Witherspoon, Melinda French Gates, Hillary Clinton and former House Speaker Nancy Pelosi have also supported the organization.

The latest film, “Miss Representation: Rise Up,” debuted earlier this month.

Trans ideology marketed as education

Newsom has portrayed his wife’s organizations as charities dedicated to helping women and girls.

Their educational materials extend well beyond that mission.

Curriculum guides include materials promoting nonbinary gender ideology, including the “Genderbread Person” graphic illustrating gender identity and expression across spectrums.

Students also participate in exercises such as the “Privilege Walk,” examining race, gender, sexual orientation and socioeconomic status.

The Representation Project states on its website: “We are here to change the world… These documentaries on limiting gender narratives have been viewed nearly 30 million times, with our film curricula changing the lives of over 2 million students.”

The site continues: “Together we are bending the long arc of history toward intersectional gender justice.”

In 2025, Siebel Newsom partnered with Positive Coaching Alliance, which has opposed bans preventing transgender athletes from competing in girls’ high school sports.

The accountability question

There is nothing inherently improper about a governor’s spouse operating nonprofit organizations.

Nor are behested payments illegal.

But Newsom’s insistence that his wife’s charities operate independently of his political world is difficult to reconcile with the available evidence.

The boards, donors, curriculum, contracts and financial relationships all point to organizations closely connected to the governor’s political network rather than operating as independent charitable ventures.

When a governor’s spouse runs nonprofits financed by companies seeking state approvals or assistance, staffed by political allies and producing films featuring the governor himself, the public is entitled to ask whether those organizations function as independent charities or as extensions of a broader political operation.

Federal investigators may ultimately decide whether any of that activity crossed the legal line.

Susan Crabtree is White House & National Political Correspondent for RealClearPolitics

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