Bloomberg has this article: Michael J. Bologna, Whistleblower Targets Tax Shelter Promoting Do-Good Technology (Bloomberg Tax 3/23/26), here. The only thing I know about the strategy is from the article. I therefore cannot speak to whether it is in fact a bullshit tax shelter. However, if the article accurately describes the strategy, it has the earmarks of bullshit tax shelters—likely gross overvaluation of charitable noncash donations—from Jackie Fine Arts in the 1970s and early 1980s, through a cousin, Barrister, then going through the Syndicated Conservation Easements.
The article appears to be well researched and has some comments by prominent attorneys in this area. Some excerpts:
Working off a playbook refined over several years, Solidaris and its partners in 2025 proposed four separate plans, each investing in 45 shell companies, and each looking to raise $90 million from wealthy investors.
In one plan, the investors could vote to donate license rights to a technology designed to help blind people navigate in urban environments. In the second, they could vote to distribute digital coloring books to pediatric cancer patients. And in the two others, they could choose to donate crime-fighting artificial intelligence technology to local police departments. All four plans were described in private placement documents as Regulation D private offerings, allowing the promoters and sponsors to raise capital without registering the investments with the Securities and Exchange Commission.
Elements of the strategy including outsized charitable deductions, complex procedures, and unusually high fees, warrant government scrutiny, according to former Internal Revenue Service, SEC, and Department of Justice officials who reviewed the documents for Bloomberg Tax.
“It undermines fundamental economics and human behavior,” said Miles Fuller, a former senior counsel at the IRS Office of Chief Counsel. “One dollar does not turn into five dollars overnight. And if it did, it is unlikely the beneficial party would then donate the five dollars to charity rather than sell and pocket the profit.”
The Solidaris-led strategy to collect $360 million total from investors last year could generate charitable deductions of $1.8 billion this tax season, assuming high-wealth investors vote to donate the technology and then claim a deduction worth five times their investments. That would cut an estimated $667 million from their federal returns and $90 million from state returns for tax year 2025.
Solidaris says its investments “multiply good on a local, state, and national scale.” It also said it plays no role in whether investors vote to donate the technology. The company has not been charged with any wrongdoing.
Under the Internal Revenue Code, whether a tax shelter is allowed or not can be an open question until the government weighs in. And that can take years, especially when the shelter is novel or complicated.
Just a few comments:
1. Bullshit tax shelters (taking no position on the particular tax strategy) are not open questions until the “government [IRS] weighs in.” They are bullshit from the inception. They work—in the sense that the contribution deductions are not challenged if the IRS does not weigh in. But, bullshit tax shelters are never open questions. And, when and if the IRS weighs in, the weigh-in will be retroactive within the applicable statute of limitations. In this regard, readers should keep in mind that, depending upon just how bullshitty the strategy is, the statute of limitations may be open. See e.g., Third Circuit Holds Taxpayer Fraud is not Required for 6501(c)(1) Unlimited Statute of Limitations, Creating Conflict (Federal Tax Procedure Blog 8/18/25; 10/17/25), here. (The statute would be open with potential for the 40% civil penalty and interest on tax and penalty from inception.)
2. If the particular strategy had been packaged as a conservation easement deduction gambit, it (as described in the article) would certainly fail.
3. Solidaris’ web site, is here. It’s Leadership page is here, The page has the following generic descriptions rather than naming members of the leadership:
Our team of tax attorneys, CPAs, and business professionals brings more than 125 years of combined experience in tax law and public accounting, with a broad range of academic and professional expertise, including degrees from respected institutions such as West Point, BYU, Loyola, Georgetown, and the University of Alabama. Our collective experience includes work with organizations such as PwC, Bank of America, Summit Partners, WordPress, the IRS, and the FBI, as well as leading and advising our own firms. We are committed to developing strategies that align with current tax law and compliance standards, enabling tax professionals to deliver innovative and compliant solutions to their clients.
You will notice that what is missing is any claim that leadership is committed to ethics, either as professionals or as citizens who, at least in theory, should want all to pay their fair share of taxes.
4. The article says that Geoffrey Dietrich is the CEO of Solidaris, also serving as “managing partner of the law firm Cantley Dietrich LLC, and founder of the investment management group Cirrus Investments LLC.” The Cantley Dietrich web page lists Dietrich as the only shareholder, here. The Professional Team page, here, shows a single member of the team, Jonathan Carris identified as “Of Counsel.” The “Contact Us” page, here, shows Dallas, Las Vegas, Salt Lake City, & Atlanta addresses. Dietrich’s LinkedIn page is here. Articles on Dietrich are: Elevated Magazine, here (picturing him on what appears to be a private jet) and an SABM Group page, here (describing Dietrich as “full-time Managing Partner of Cantley Dietrich, PC, a national boutique law firm of experienced tax attorneys servicing high net-worth individuals.”)
5. Again, I caveat that I cannot say the particular strategy is a bullshit tax shelter because all I know of it is what I read in the article and the article may not be a fair presentation of the strategy. All I am saying is that, as presented in the article, the strategy has characteristics of bullshit tax shelters.
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