Nick Penzenstadler, Steve Reilly, and John Kelly

USA TODAY

LAS VEGAS — President Trump’s companies own more than 400 condo units and home lots whose sale could steer millions of dollars to Trump, a USA TODAY investigation has found.

USA TODAY spent four months cataloging every property Trump's companies own across the country. Reporters found that Trump’s companies are sitting on at least $250 million of individual properties in the USA alone. Property records show Trump’s trust and his companies own at least 422 luxury condos and penthouses from New York City to Las Vegas, 12 mansion lots on bluffs overlooking his golf course on the Pacific Ocean and dozens more smaller pieces of real estate. The properties range in value from about $200,000 to $35 million each.

Unlike developments where Trump licenses his name to a separate developer for a flat fee, profits from selling individual properties directly owned by his companies ultimately enrich him personally.

Trump has never disclosed a complete, unit-by-unit inventory of his companies' real estate holdings or sales, nor is he required to do so by federal law. Trump says he's separated himself from his businesses, but the trust set up in January is run by his sons. Trump is the only beneficiary and can withdraw funds at any time.

The volume of real estate creates an extraordinary and unprecedented potential for people, corporations or foreign interests to try to influence a president. Anyone who wanted to court favor with the president could snap up multiple properties or purposefully overpay. They could buy in the name of a shell company, making it impossible for the public to know who was behind the sales.

The potential for conflicts is exacerbated by Trump's refusal to release his tax returns or fully separate himself from his businesses, breaking with precedent set by presidents going back four decades. Since Congress passed the Ethics in Government Act in 1978, all six presidents from Carter to Obama established blind trusts or limited investments to assets like mutual funds. Trump has not.

The president is exempt from most conflict-of-interest laws that apply to others working in the federal government. He is not required to disclose when units sell or who bought them.

He is barred by the Constitution from receiving gifts from foreign governments or officials. Trump’s assessment that the ban doesn’t apply to market-rate transactions is debated in lawsuits and among ethics experts.

Regardless, it may be impossible for the public to even know who is behind purchase because the rules governing real estate transactions allow for shell companies to make purchases without disclosing who actually paid the money.

“Anyone seeking to influence the president could set up an anonymous company and purchase his property,” said Heather Lowe, director of government affairs at Global Financial Integrity, a D.C.-based group aimed at curbing illicit financial transactions. “It’s a big black box, and the system is failing as a check for conflicts of interest.”

Since Election Day, records show Trump companies have sold at least 14 luxury condos and home-building lots for about $23 million. Half were sold to limited liability companies. No names were listed in deeds, obscuring buyers’ identities.

Since launching his White House bid, Trump’s companies have sold at least 58 units nationwide for about $90 million. Almost half of those sold to LLCs.

That doesn’t count Trump's ownership of millions of square feet of some of America’s priciest office and retail rental space in Manhattan, Chicago and San Francisco.

Buyers and renters of Trump properties include companies or individuals tracing to addresses in at least a dozen countries.

The White House refers business inquiries to the Trump Organization, where four separate executives and spokesmen declined to answer specific questions.

Bobby Burchfield, an attorney hired as an independent ethics reviewer for Trump Organization business deals, wouldn’t answer specific questions about transactions.

Trump attorneys have argued that profits from individual real estate sales would route through a maze of Trump subsidiaries and eventually become mixed in a larger pool of undifferentiated money in the president’s trust. That, they say, makes a direct conflict from an individual sale more difficult to imagine. They do not consider sales of U.S. real estate to foreign investors as “foreign deals."

Those in the business of selling Trump-owned real estate say business is up.

“I get a lot more phone calls now that he’s the president,” said Shari Sanderson, a real estate agent that sells units in the Las Vegas hotel-condo tower.

A mysterious bulk buyer

A couple of weeks before the Republican National Convention, a Las Vegas financial firm filed paperwork to found Milan Investment Limited in Nevada.

Days later, the newly minted company went on a buying spree. Milan spent $3.1 million over four months to buy 11 luxury condos in a shimmering golden tower near the Strip that Trump owns with friend and casino mogul Phil Ruffin. Trump Ruffin LLC collected the last of the money weeks before Trump was elected.

Milan Investment tracks back to what appears to be an incorrect address, the strip mall office of a financial services firm.

The owner, Thomas Sullivan, said he never heard of Milan Investment but said a federal “regulatory” agency visited his office in person asking similar questions. He declined to identify the agency.

“We’re completely in the dark,” Sullivan said. “We don’t know if it was a mistake, or they used our address for some reason, but we aren’t associated with them.”

On the deeds from Milan’s purchases, Eric Trump signed for the sellers. An accountant signed for the buyers, and deeds do not identify any people behind Milan.

USA TODAY tracked corporate, loan and property records across Nevada, Texas and Canada to tie three names to Milan Investment.

In Nevada, where rules let anyone form companies without identifying the owners, Milan’s officers are listed as Jun Xu and Qi Huang with an address at an office suite on the outskirts of Las Vegas.

Additional documents underlying the sale give two more addresses, both million-dollar condos in Vancouver, for Xu and Huang. Canadian records indicate they own both and hold a license to rent one. The records list Xu as a “businessman” and Huang as a “housewife.”

USA TODAY contacted every phone number and address found for Xu and Huang in two countries. Reporters also contacted every business associate identified in Nevada public records as having worked with the company or assisted with the condo buys, trying to reach Xu and Huang or find out more about them. Xu and Huang have not responded.

One more name tied to Milan is Chen Huang of Sugar Land, Texas, who signed loan documents “on behalf of Jun Xu and Qi Huang” when they borrowed money using the Vegas condos as collateral. Phone numbers for Chen Huang in Texas were answered but disconnected after a reporter identified himself.

Most Nevada real estate and legal professionals who handled deals would not answer questions. A lawyer who reviewed paperwork for the lender, Michael Wixom, said only, “We file the UCC paperwork and represent the bank locally. It’s all consistent with Nevada state law, and it’s not unusual to not know the name of the owners.”

Reporters sent questions about the identity-obscuring real estate sales to a public relations firm representing Trump in New York, the Trump Organization’s marketing vice president, its vice president of sales in Las Vegas and Eric Trump. None of the inquiries was answered.

The deal in 2016 makes Milan Investment the third-biggest investor in the Vegas building, behind Trump’s own company and Hilton Hotels, which owns 311 of the condos.

Kathleen Clark, a government ethics expert and professor at Washington University School of Law, said there’s a strong argument for requiring disclosure of anyone buying real estate from the president.

“They’re doing it through Trump companies, but nevertheless, if it’s going to benefit the president, I think the public has a right to know who’s paying the president,” Clark said. One solution: making the president subject to the same rules as other public officials.

Who's buying from Trump?

USA TODAY’s review of sales of Trump-owned real estate found dozens of transactions during and since the campaign involving buyers who have business in or connections with foreign countries, or are shielded by purchasing under the name of an LLC. None of the recorded sales prices appeared, on the surface, to be outside market value.

In February, businesswoman Xiao Yan Chen bought one of the president’s penthouses at Trump Park Avenue in Manhattan for $15.9 million, according to city records.

Chen is founder and managing director of Global Alliance Associates, a New York City firm described on its website as “a boutique business relationship consultancy for U.S. companies seeking to establish a presence in mainland China.” She could not be reached for comment.

A few days before Trump’s inauguration, a two-bedroom condo on the 55th floor of the Las Vegas tower sold for $639,000. The buyer of Condo No. 5507 is identified in deeds as Fashion Drive, a New York company named for the street below and formed days before the purchase.

The only real person named in company's corporate filings in New York is Ivan Antonevich, a Ukrainian-educated pain doctor who did not reply to interview requests. It’s unclear whether he owns the condo, represents the buyer, or something else happened.

As part of a federal crackdown on criminals using real estate to hide illicit cash, title insurance companies in a handful of U.S. cities must gather identity information and report all-cash deals above certain amounts to the government. Industry insiders said the opacity of most shell company real estate buys is for practical, legitimate reasons.

“Privacy is a big driver of the LLCs, whether it’s celebrities protecting their privacy or foreign dissidents hiding assets from an oppressive government or law enforcement officers worried about their safety from criminals,” said Steve Gottheim, senior counsel at the American Land Title Association.

Some investors in the Vegas building were easy to track down and willing to talk. One New York couple set up a company, SNJ Properties, to buy a unit in December. SNJ is owned by Susan and John Irwin of East Islip, N.Y., who bought a second condo in the building for vacation and as an investment. They said it didn’t have much to do with politics.

“I’m a big fan of his, but the fact that Trump is president didn’t influence our decision,” said John Irwin, who owns Irwin Construction. Irwin, who met Trump at the hotel once, said he doesn’t worry about other people’s blind purchases of Trump’s real estate. “It doesn’t bother me. He’s a businessman, and that’s who we elected.”

Trump’s leasable space in cities such as New York, Chicago and San Francisco bring in large sums as well. Commercial space at Trump Tower earned him almost $30 million in 2012, according to a filing with the Securities and Exchange Commission to back up a loan Trump took out against the space.

Among the revenue: multimillion-dollar lease payments from the communist government-owned Industrial & Commercial Bank of China.

The Chinese bank’s lease is one of several transactions flagged in a lawsuit against Trump by an ethics watchdog group, alleging Trump violates the Emoluments Clause of the U.S. Constitution, which forbids government officials from taking gifts from foreign powers.

More deals ready to be made

The White House and Trump surrogates have broadly contended that the president is not involved in his business deals and scoff at the idea that a billionaire tycoon could be influenced by individual real estate transactions in the six- or seven-figure range.

The USA TODAY review of publicly available records — including figures provided by the president himself — shows that his individual real estate transactions add up and have substantially driven his income in recent years.

Consider the Vegas tower. In his federal financial disclosure in 2016, the income Trump said he received from the Vegas venture is more than the revenue he reported from all but one of his approximately 500 companies.

USA TODAY’s analysis of the 2016 report indicates Trump’s income includes at least $100 million a year from real estate sales and lease transactions. That number is probably higher because companies’ income is reported in ranges spanning millions of dollars.

Trump and his daughter Ivanka have reported drawing multimillion-dollar incomes from Trump International Realty in recent years. Trump’s financial disclosure reported about $4 million in commissions in 2016, and Jared Kushner’s disclosure reports his wife earns $1 million to $5 million a year in commissions and fees from the firm.

At Trump properties across the country, more deals are ready to be made.

“We’re selling quite a few of those now,” Ruffin said of the partners’ Vegas tower, where he and Trump own 388 condos and penthouses. “It’s picked up, our volume.” Ruffin owns an adjacent lot and is interested in building another tower and casino there, possibly partnering with the Trump Organization.

In total, records show Trump and his family own 32 residential condo units, plus 82 additional smaller units of real estate, including commercial property and storage spaces across New York City. That’s where the biggest money transactions are in the making.

Trump’s realty company lists one of his three-bedroom condos on the seventh floor of Trump Park Avenue for $7 million, touting solid oak floors, handcrafted Italian brass doorknobs, marble baths and “a sleek gourmet chef’s kitchen.” Also for sale: a Trump-owned seven-bedroom penthouse on the 32nd floor. The $75,000-a-month rent gets you “360-degree views of New York City’s stunning landscape.”

At 100 Central Park South, beneath the facade bearing the words “Trump Parc” in gold script, placards recently filled the windows advertising “RETAIL SPACE FOR LEASE.” The rent: $1.3 million a year.

Joanne Podell, the listing agent for Cushman & Wakefield, said that although there has been recent interest, the building’s powerful owner is far less important in attracting tenants as factors like foot traffic and size. “It’s a great location."