Ivanka Trump or her trust received at least $12.6 million since early 2016 from her various business ventures and has an arrangement to guarantee her at least $1.5 million a year even as she serves in a top White House position, according to her first ethics disclosure made public late Friday.
The report was released alongside an updated filing by her husband, Jared Kushner, who is also serving as a top adviser to President Trump. It shows that the couple benefit from an active business empire worth as much as $761 million to them, an arrangement that ethics experts warn poses potentials for conflicts of interest as the couple have been given a wide-ranging portfolio of government responsibilities.
Ms. Trump, who resigned from nearly 300 leadership positions at various entities within the family real estate businesses and at her fashion brand, has continued to receive millions of dollars from both streams, including more than $2.4 million from her stake in the Trump International Hotel in Washington and more than $2.5 million in salary and severance from the Trump Organization.
Ms. Trump received about $1.7 million in payments from T International Realty, the family's luxury brokerage agency, as well as two other real estate companies for various management, consulting and licensing work, the documents show. Those payments, for work done in 2016, were based on the companies' performance.
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But going forward, she will receive fixed payments — a change that her advisers say was developed in consultation with the Office of Government Ethics to minimize her potential conflicts by removing her interest in how well her family's business performs.
In total, Ms. Trump will receive $1.5 million in fixed payments from the same three real estate entities. She stands to earn additional income from her stake in the hotel in Washington.
The disclosures provided less specific figures for Ms. Trump's earnings from her fashion brand, which were reported in ranges. From the beginning of last year to May 31 of this year, she or her trust earned at least $6 million from sales of her clothes, shoes and other accessories. Ms. Trump rolled her brand into the trust, which is overseen by Joshua Kushner and Nicole Meyer, her brother-in-law and sister-in-law, in March.
The income reported by Ms. Trump does not reflect expenses associated with the underlying businesses.
Those payments will keep coming, albeit into the trust. Ms. Trump also receives regular reports on the performance of her brand, which is overseen by its president, Abigail Klem.
Although the documents show Ms. Trump's personal assets, income and liabilities, they do not disclose her brand's fashion licensing partners, for example, or real estate clients. Such information is not required, demonstrating the limits of such disclosures for government officials with vast business interests.
"There still may be financial ties that we don't know about," said Lawrence M. Noble, a former general counsel and chief ethics officer of the Federal Election Commission. "These really weren't meant to deal with a situation where somebody's going to keep a major business interest."
Mr. Kushner divested his interests in some assets owned by his family's real estate firm, Kushner Companies, but he remains heavily invested in the bulk of the businesses. The disclosures provide another clue into how active the multibillion-dollar Kushner family real estate business remains. Since March, companies in which he remains invested have closed several real estate deals across the country, including the sale of properties in Toledo, Ohio, for $5 million to $25 million and a purchase in Brooklyn also worth as much as $25 million to him.
Mr. Kushner disclosed the scope of his business in his first ethics report in March. In the new, amended filing released on Friday, he disclosed the existence of dozens of subsidiaries he did not report previously, generally connected to entities he revealed in that first report. In that report, he stated that the couples' holdings were worth about $736 million, about $25 million less than in the updated report.
The documents also offered tidbits about less significant sources of Ms. Trump's income. She received $50,000 for helping to oversee a trust belonging to children of Rupert Murdoch, the executive chairman of 21st Century Fox, and his former wife Wendi Deng, her close friend. Ms. Trump resigned as a trustee last year.
She also received $787,500 as an advance for her book "Women Who Work," although it is not clear what portion of her total advance that represents.
In total, the couple reported as much as $212 million in income since early 2016, according to new and previous filings. The bulk of that number comes from Mr. Kushner's holdings.
Ethics experts say the extensive holdings of the two pose potential conflicts of interest. Unlike Mr. Trump, who is exempt from federal ethics laws, Mr. Kushner and Ms. Trump are prohibited by those laws from taking any government action that might benefit their financial holdings.
Mr. Kushner and Ms. Trump both "walk a very fine line in having to step aside and recuse themselves from certain discussions and give advice if it would benefit them and their business personally," said Scott H. Amey, the general counsel at the Project on Government Oversight, a nonprofit organization.
"And we won't know if they are taking necessary steps to recuse themselves because, unfortunately, the ethics process requires a lot of self-policing," he said.
Jamie Gorelick, a partner at WilmerHale who is advising the couple on complying with government ethics requirements, said in a statement: "Jared and Ivanka have followed each of the required steps in their transition from private citizens to federal officials. The Office of Government Ethics has certified Jared's financial disclosure, reflecting its determination that his approach complies with federal ethics laws. Ivanka's financial disclosure form is still in the pre-certification stage, as she began the process later, but discussions with O.G.E. are proceeding in the ordinary course."
In just the first few months of the administration, the couple's business connections have already raised questions. In February, the presidential adviser Kellyanne Conway appeared on live television and urged viewers to buy fashion products marketed by Ms. Trump. And in May, Mr. Kushner's sister cited his White House connections when she visited China to solicit potential investors through a "visa for sale" program run by the federal government for a development project in New Jersey to be built by the family's real estate firm.
The hotel in Washington is a particular point of consternation. There are concerns that businesses or foreign leaders might try to curry favor with the administration by spending money at the hotel. At least one lawsuit claims that Mr. Trump's ownership violates the emoluments clause of the Constitution, which bars federal officials, including the president, from accepting payments from foreign governments.