How did some nonprofit organizations avoid disclosing donors after Citizens United?

Following the Citizens United ruling, some political nonprofit corporations evaded disclosure requirements by reregistering with the Internal Revenue Service as tax-exempt "social welfare" organizations. Under this classification, these groups were not required to publicly disclose the identities of their donors.12

Additionally, many of these corporations maintained their existing tax status but accepted large contributions from "sham" social welfare organizations. These intermediary groups were specifically created to collect and distribute anonymous funds, a practice that fueled the rise of "dark money" in political campaigns. While the Supreme Court had expressed faith that disclosure requirements would provide transparency for shareholders and the public, these strategies allowed significant amounts of money to be spent on elections without revealing the original sources of the funding.12