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  • FEC Record: Advisory opinions

AO 2022-24: Contributions from an irrevocable trust

December 15, 2022

A proposed irrevocable trust to be established by Allen Blue may make contributions to federal candidates and political committees under the indexed contribution limits in effect at the time that the trust makes the contribution. If the trustees select the recipient, the contributions are attributed only to the trust. Contributions made to “designated recipients” based on the objective criteria set forth in the trust instrument are attributed both to the trust and to Mr. Blue.


Allen Blue is a United States citizen and is eligible to make contributions. He proposes to create an irrevocable trust to support nonprofit organizations that align with his values. In additional to its nonprofit contributions, the trust may make contributions to state and federal political committees.

Consistent with previous advisory opinions, the Commission determined that the irrevocable trust may contribute to federal candidates, political party committees, and other federally registered committees under the Federal Election Campaign Act (the Act) and Commission regulations because the trust would be a “person” under the Act and is not a prohibited source.

The Commission also concluded that contributions from the trust should be attributed to the trust alone when they are made at the broad discretion of its trustees, whereas other contributions made to “designated recipients” pursuant to “objective criteria set forth in the trust instrument” should be attributed to both the trust and Mr. Blue. In either case, the contributions should not be attributed to the trustees.

Date Issued: December 1, 2022; Length: 8 pages


  • Author 
    • Don Michael
    • Communications Specialist