The ever-hard to track Citizens for a Working America, last seen in Iowa making a big Christmas Eve ad buy on behalf of GOP presidential candidate Mitt Romney, has resurfaced in a new-old incarnation.

Confused? So were we, when we last wrote about this shadowy organization. No wonder.

Turns out that the name Citizens for a Working America is shared by two linked but distinct entities:

• Citizens for a Working America PAC, a super PAC that first surfaced in 2010 when it helped defeat veteran Democratic Rep. John Spratt, a South Carolina Democrat who chaired the House Budget Committee, and
• Citizens for a Working America Inc., a nonprofit 501(c)4 corporation that made a $475,000 media buy in support of to Romney days before the Jan. 3 Iowa caucus after earlier signaling that it might support rival Republican presidential candidate Michele Bachmann's now defunct campaign.

Phew. Glad we got that sorted out. But just who is underwriting these twin committees remains a mystery. Under federal law, the super PAC must disclose its donors to the FEC, it has only listed two: Citizens for a Working America Inc. and New Models, another 501c4. Because they are organized as non-profit "social welfare" organizations under the IRS tax code, neither is required to make public where it gets its money.

Ten days before South Carolina's critical Jan. 21 GOP primary, when Newt Gingrich was surging on the strenght of his super PAC's attacks on Romney's work for Bain Capital, Citizens for a Working America PAC got $163,000 from Citizens for a Working America Inc. and another $292,000 from New Models.  A day after receiving the contributions, the super PAC used the entire $455,000 for a South Carolina media buy in support of Romney. You can see the transactions for yourself on Sunlight's Follow the Unlimited Money tracker.

Here's who we know is behind the groups: Norm Cummings, an experienced GOP strategist with Ohio roots, owns a Chesapeake Bay waterfront home listed as the address for Citizens for a Working America PAC. But in a cryptic interview with Sunlight earlier this year, Cummings suggested the operation had relocated to Ohio. Citizens for a Working America Inc. lists its address as Dayton, Ohio and Cummings as its treasurer. According to a listing on Guidestar, a nonpartisan organization that tracks nonprofits, it had $2.3 million in revenues last year.

The 501(c) 4, which lists Cummings as treasurer, rebuffed an effort by the FEC to learn the names of its contributors, hewing to a narrow interpretation of the law that seems likely to get no challenge from a gridlocked FEC. 

Cummings is one of two salaried officials listed on New Models' most recent filing with the Internal Revenue Service. The other is Tim Crawford, another seasoned Republican campaign veteran who serves as an advisor to Sarah Palin. Crawford, who says Palin is not connected to New Models, described it as doing "research on national issues." New Models has been involved, via Citizens for a Working America, in the campaign to elect Romney and the campaign to defeat Spratt. Its biggest play, however, appears to have been bankrolling a successful effort to block state-run gambling in Ohio to the tune of nearly $1.6 million.

That set off a court fight to force disclosure of the campaign's sources of funding. But the Democratic secretary of state and attorney general who launched the legal effort have since been replaced by Republicans and the case has “done away,” according to John Burtch, the Ohio lawyer who represented New Models in the case.  

Crawford makes no apologies for not making his donors public. "We disclose our donors to the IRS," he said, noting that no further exposure is legally required (the IRS does not release information on income of 501c4s). "If the law changes, we will change," said Crawford. As to why his group donated this year to Citizens for a Working America, Crawford said, "I'm not going to comment."

He said he's not sure whether New Models will be active in other campaigns this year.