Fact is, not one person has offered a reasonable rebuttal beyond saying what is being said on this thread is non-factual!
Facts as I see them: Drake 'gifted' 196,255,000 shares to a charity fund. This gift is irrevocable - meaning it cannot be reversed or changed. This is not a holding trust, it is a 'giving' trust.
Drake have lodged a Change in Substantial holder notice, meaning they no longer hold an interest in those shares. Drake have signed over legal control to the NPT, clearly stated in the below link from the NPT, and also publicly via the change in sub holder notice.
The taxable benefit is the fair value price of the gift recorded at the time of donation. This can be used against 30% of the company AGI.