Department of the Treasury Internal Revenue Service
Public Charity Status and Public Support
Complete if the organization is a section 501(c)(3) organization or a section
4947(a)(1) nonexempt charitable trust.
Attach to Form 990 or Form 990-EZ. See separate instructions.
OMB No. 1545-0047
2010
Open to Public Inspection
Name of the organization
VETERANS OF FOREIGN WARS FOUNDATION
Employer identification number
43-1758998
Part I
Reason for Public Charity Status
(All organizations must complete this part.) See instructions
The organization is not a private foundation because it is: (For lines 1 through 11, check only one box.)
1
2
3
4
5
section 170(b)(1)(A)(iv). (Complete Part II.)
6
7
8
9
receipts from activities related to its exempt functions—subject to certain exceptions, and (2) no more than 331/3% of
its support from gross investment income and unrelated business taxable income (less section 511 tax) from businesses
acquired by the organization after June 30, 1975. See section 509(a)(2). (Complete Part III.)
10
11
e
By checking this box, I certify that the organization is not controlled directly or indirectly by one or more disqualified persons other than foundation managers and other than one or more publicly supported organizations described in section 509(a)(1) or section 509(a)(2).
f
If the organization received a written determination from the IRS that it is a Type I, Type II or Type III supporting organization, check this box
..................................................
g
Since August 17, 2006, has the organization accepted any gift or contribution from any of the following persons?
(i) a person who directly or indirectly controls, either alone or together with persons described in (ii)
Yes
No
and (iii) below, the governing body of the the supported organization?
................
11g(i)
(ii)
a family member of a person described in (i) above?
......................
11g(ii)
(iii)
a 35% controlled entity of a person described in (i) or (ii) above?
................
11g(iii)
h
Provide the following information about the supported organization(s).
(i) Name of supported organization
(ii) EIN
(iii) Type of organization (described on lines 1- 9 above or IRC section (see instructions))
(iv) Is the organization in col. (i) listed in your governing document?
(v) Did you notify the organization in col. (i) of your support?
(vi) Is the organization in col. (i) organized in the U.S.?
(vii) Amount of support?
Yes
No
Yes
No
Yes
No
Total
For Paperwork Reduction Act Notice, see the Instructions for Form 990.
Cat. No. 11285F
Schedule A (Form 990 or 990-EZ) 2010
Schedule A (Form 990 or 990-EZ) 2010
Page 2
Part II
Support Schedule for Organizations Described in IRC 170(b)(1)(A)(iv) and 170(b)(1)(A)(vi) (Complete only if you checked the box on line 5, 7, or 8 of Part I or if the
organization failed to qualify under Part III. If the organization fails to
qualify under the tests listed below, please complete Part III.)
Section A. Public Support
Calendar year(or fiscal year beginning in)
(a) 2006
(b) 2007
(c) 2008
(d) 2009
(e) 2010
(f) Total
1
Gifts, grants, contributions, and membership fees received. (Do not include any "unusual grants.") ....
9,993,581
4,714,286
6,793,760
4,033,644
5,173,831
30,709,102
2
Tax revenues levied for the organization's benefit and either paid to or expended on its behalf.......
3
The value of services or facilities furnished by a governmental unit to the organization without charge..
4
Total. Add lines 1 through 3..
9,993,581
4,714,286
6,793,760
4,033,644
5,173,831
30,709,102
5
The portion of total contributions by each person (other than a governmental unit or publicly supported organization) included
on line 1 that exceeds 2% of the amount shown on line 11, column (f)..
14,314,617
6
Public Support. Subtract line 5 from line 4.
16,394,485
Section B. Total Support
Calendar year(or fiscal year beginning in)
(a) 2006
(b) 2007
(c) 2008
(d) 2009
(e) 2010
(f) Total
7
Amounts from line 4..
9,993,581
4,714,286
6,793,760
4,033,644
5,173,831
30,709,102
8
Gross income from interest, dividends, payments received on securities loans, rents, royalties and income from similar sources..
35,855
57,289
53,959
50,141
74,275
271,519
9
Net income from unrelated business activities, whether or not the business is regularly carried on..
10
Other income. (Explain in Part IV.) Do not include gain or loss from the sale of capital assets..
11
Total support (Add lines 7 through 10).
30,980,621
12
Gross receipts from related activities, etc. (See instructions.)
..................
12
13
First Five Years
If the Form 990 is for the organization's first, second, third, fourth, or fifth tax year as a 501(c)(3) organization,
check this box and stop here..........................................
Section C. Computation of Public Support Percentage
14
Public Support Percentage for 2010 (line 6 column (f) divided by line 11 column (f))
.........
14
52.920 %
15
Public Support Percentage for 2009 Schedule A, Part II, line 14
...............
15
55.620 %
16a
33 1/3% support test—2010.
If the organization did not check the box on line 13, and line 14 is 33 1/3% or more, check this box
and stop here. The organization qualifies as a publicly supported organization
......................
b
33 1/3% support test—2009.
If the organization did not check the box on line 13 or 16a, and line 15 is 33 1/3% or more, check this
box and stop here. The organization qualifies as a publicly supported organization
.....................
17a
10%-facts-and-circumstances test—2010.
If the organization did not check a box on line 13, 16a, or 16b and line 14
is 10% or more, and if the organization meets the "facts and circumstances" test, check this box and stop here. Explain
in Part IV how the organization meets the "facts and circumstances" test. The organization qualifies as a publicly supported
organization
..................................................
b
10%-facts-and-circumstances test—2009.
If the organization did not check a box on line 13, 16a, 16b, or 17a and line
15 is 10% or more, and if the organization meets the "facts and circumstances" test, check this box and stop here.
Explain in Part IV how the organization meets the "facts and circumstances" test. The organization qualifies as a publicly supported organization
..............................................
18
Private Foundation
If the organization did not check a box on line 13, 16a, 16b, 17a or 17b, check this box and see
instructions
...................................................
Schedule A (Form 990 or 990-EZ) 2010
Schedule A (Form 990 or 990-EZ) 2010
Page 3
Part III
Support Schedule for Organizations Described in IRC 509(a)(2) (Complete only if you checked the box on line 9 of Part I or if the organization
failed to qualify under Part II. If the organization fails to qualify under
the tests listed below, please complete Part II.)
Section A. Public Support
Calendar year(or fiscal year beginning in)
(a) 2006
(b) 2007
(c) 2008
(d) 2009
(e) 2010
(f) Total
1
Gifts, grants, contributions, and membership fees received. (Do not include any "unusual grants.") .
2
Gross receipts from admissions, merchandise sold or services performed, or facilities furnished in any activity that is related to the organization's tax-exempt purpose......
3
Gross receipts from activities that are not an unrelated trade or business under section 513..
4
Tax revenues levied for the organization's benefit and either paid to or expended on its behalf...
5
The value of services or facilities furnished by a governmental unit to the organization without charge..
6
Total. Add lines 1 through 5.
7a
Amounts included on lines 1, 2, and 3 received from disqualified persons...
b
Amounts included on lines 2 and 3 received from other than disqualified persons that exceed the greater of $5,000 or 1% of the amount on line 13 for the year.
c
Add lines 7a and 7b..
8
Public Support (Subtract line 7c from line 6.)
Section B. Total Support
Calendar year (or fiscal year beginning in)
(a) 2006
(b) 2007
(c) 2008
(d) 2009
(e) 2010
(f) Total
9
Amounts from line 6...
10a
Gross income from interest, dividends, payments received on securities loans, rents, royalties and income from similar sources..
b
Unrelated business taxable income (less section 511 taxes) from businesses acquired after June 30, 1975.
c
Add lines 10a and 10b.
11
Net income from unrelated business activities not included in line 10b, whether or not the business is regularly carried on.
12
Other income. Do not include gain or loss from the sale of capital assets (Explain in Part IV.)
13
Total support (Add lines 9, 10c, 11 and 12.).
14
First Five Years
If the Form 990 is for the organization's first, second, third, fourth, or fifth tax year as a 501(c)(3) organization,
check this box and stop here.............................................
Section C. Computation of Public Support Percentage
15
Public Support Percentage for 2010 (line 8 column (f) divided by line 13 column (f))
.........
15
16
Public support percentage from 2009 Schedule A, Part III, line 15
...............
16
Section D. Computation of Investment Income Percentage
17
Investment income percentage for 2010 (line 10c column (f) divided by line 13 column (f))
......
17
18
Investment income percentage from 2009 Schedule A, Part III, line 17
.............
18
19a
33 1/3% support tests—2010.
If the organization did not check the box on line 14, and line 15 is more than 33 1/3% and line 17 is not more than 33 1/3%, check this box and stop here. The organization qualifies as a publicly supported organization
..........
b
33 1/3% support tests—2009.
If the organization did not check a box on line 14 or line 19a, and line 16 is more than 33 1/3% and line 18 is not more than 33 1/3%, check this box and stop here. The organization qualifies as a publicly supported organization
....
20
Private Foundation
If the organization did not check a box on line 14, 19a or 19b, check this box and see instructions
.....
Schedule A (Form 990 or 990-EZ) 2010
Schedule A (Form 990 or 990-EZ) 2010
Page 4
Part IV
Supplemental Information.
Supplemental Information. Complete this part to provide the explanation required by Part II, line 10; Part II, line 17a or 17b; or Part III, line 12. Also complete this part for any additional information. (See instructions).
Facts And Circumstances Test
Explanation
Schedule A (Form 990 or 990-EZ) 2010
Additional Data
Software ID:
Software Version:
-
TIN:
SCHEDULE O (Form 990 or 990-EZ)
Department of the Treasury Internal Revenue Service
Supplemental Information to Form 990 or 990-EZ
Complete to provide information for responses to specific questions on
Form 990 or to provide any additional information.
Attach to Form 990 or 990-EZ.
OMB No. 1545-0047
2010
Open to Public Inspection
Name of the organization
VETERANS OF FOREIGN WARS FOUNDATION
Employer identification number
43-1758998
Identifier
Return Reference
Explanation
FORM 990 PART V, LINE 2A:
FOR EASE OF ADMINISTRATION AND IN ORDER TO PROVIDE BENEFITS, THE VETERANS OF FOREIGN WARS OF THE UNITED STATES PROVIDES ITS EMPLOYEES TO THE FOUNDATION. THEY WORK EXCLUSIVELY FOR THE FOUNDATION AND ON FOUNDATION BUSINESS AND ACTIVITIES. THE VFW FOUNDATION HAS NO EMPLOYEES OF ITS OWN. THE FOUNDATION REIMBURSES THE VETERANS OF FOREIGN WARS OF THE UNITED STATES FOR THE SALARY AND BENEFIT EXPENSES OF THOSE EMPLOYEES. THEREFORE, THE W-3 TRANSMITTAL AND W-2 FORMS ARE FILED BY THE VETERANS OF FOREIGN WARS OF THE UNITED STATES AND NOT THE VFW FOUNDATION. AS OF 12/31/10, THERE WERE SEVEN EMPLOYEES INCLUDED IN THE W-3 FILING MADE BY THE VETERANS OF FOREIGN WARS OF THE UNITED STATES THAT WORK EXCLUSIVELY FOR THE VFW FOUNDATION, AND THE EXPENSES FOR THOSE SEVEN EMPLOYEES ARE REFLECTED IN THIS RETURN.
FORM 990, PART VI, SECTION B, LINE 11
THIS 990 WAS PREPARED BY AN INDEPENDENT CERTIFIED PUBLIC ACCOUNTANT WHO WORKED WITH PROFESSIONAL EMPLOYEES IN THE ACCOUNTING DEPARTMENT OF THE VFW NATIONAL HEADQUARTERS. IT WAS REVIEWED BY THE PRINCIPAL OFFICERS OF THE ORGANIZATION PRIOR TO EXECUTION. IN ADDITION, A COPY WAS PROVIDED TO EACH MEMBER OF THE BOARD OF DIRECTORS PRIOR TO THE TIME OF FILING FOR THEIR REVIEW. THE FORM 990, ALONG WITH AUDITED FINANCIAL STATEMENTS, ARE REVIEWED WITH THE BOARD OF DIRECTORS AT A LATER, STATED MEETING.
FORM 990, PART VI, SECTION B, LINE 12C
IN ORDER TO SUSTAIN THE VETERANS OF FOREIGN WARS FOUNDATION'S REPUTATION AND CONTINUED SUCCESS, OFFICERS, DIRECTORS, AND EMPLOYEES IN LEADERSHIP POSITIONS ARE EXPECTED TO CONDUCT THEMSELVES IN A PROFESSIONAL MANNER AND ADHERE TO THE HIGHEST STANDARDS OF HONESTY AND INTEGRITY. ALL OF THE ABOVE NAMED INDIVIDUALS ARE REQUIRED TO EXECUTE AN APPROPRIATE ACKNOWLEDGEMENT OF ADHERENCE TO A CODE OF ETHICS POLICY UPON ASSUMING THEIR POSITIONS AND OFFICERS, DIRECTORS, AND KEY EMPLOYEES ARE REQUIRED TO MAKE ANNUAL DISCLAIMER OR DISCLOSURE OF CONFLICTS OF INTEREST IN ACCORDANCE WITH THE INTERNAL REVENUE SERVICE GUIDELINES. FOR THE FISCAL YEAR COVERED BY THIS FORM 990, THERE WERE NO CONFLICTS OF INTEREST IDENTIFIED BY THE INDIVIDUALS COVERED BY THIS POLICY.
FORM 990, PART VI, SECTION C, LINE 18
THE VETERANS OF FOREIGN WARS FOUNDATION COMPLIES WITH IRC SECTION 6104 AND MAKES ITS FORM 1023 AND FORM 990 AVAILABLE FOR PUBLIC INSPECTION UPON REQUEST.
FORM 990, PART VI, SECTION C, LINE 19
THESE DOCUMENTS ARE AVAILABLE, UPON REQUEST, TO MEMBERS OF THE VETERANS OF FOREIGN WARS OF THE UNITED STATES.
FORM 990, PART VII, SECTION A, LINE 1A:
JOHN LOWE IS ONE OF THE EMPLOYEES REFERENCED ABOVE FOR PART V, QUESTION 2A. MR. LOWE IS THE DIRECTOR OF THE VFW FOUNDATION, BUT HIS PAYROLL IS PROCESSED THROUGH THE VETERANS OF FOREIGN WAR'S PAYROLL SYSTEM AND THE VFW FOUNDATION REIMBURSES THE VFW OF THE U.S. FOR THESE EXPENSES. SINCE PAYMENTS ARE MADE FROM THE VFW OF THE U.S., THE W-2 FOR THE EMPLOYEE IS FROM THE VFW OF THE U.S., AND THEREFORE, THIS COMPENSATION IS INCLUDED IN COLUMN E.
CHANGES IN NET ASSETS OR FUND BALANCES:
FORM 990, PART XI, LINE 5:
NET UNREALIZED GAINS ON INVESTMENTS: 70,120.
FORM 990, PART XII, QUESTION 2(C):
THE VFW NATIONAL HEADQUARTERS ESTABLISHED AN AUDIT COMMITTEE THAT ASSUMES THE RESPONSIBILITY FOR OVERSIGHT OF THE AUDIT AND SELECTION OF THE INDEPENDENT ACCOUNTANT FOR THE VFW AND VFW FOUNDATION AUDIT.
FORM 990, PART VII, SECTION A, LINE 4:
IN DECEMBER 2011, THE VFW FOUNDATION BOARD OF DIRECTORS VOTED ON AND APPROVED CHANGES TO THE MAKE-UP OF THE EXISTING BOARD. THE TOTAL NUMBER OF BOARD MEMBERS WAS REDUCED TO EIGHT; AND FIVE OF THOSE EIGHT MEMBERS ARE INDEPENDENT MEMBERS. WHILE THIS CHANGE DOES IMPACT THE VFW FOUNDATION'S ORGANIZATIONAL DOCUMENTS AND STRUCTURE OF ITS BOARD OF DIRECTORS, THE CHANGE IS DETERMINED TO BE NOT SIGNIFICANT.
For Paperwork Reduction Act Notice, see the Instructions for Form 990 or 990-EZ.