2025-02-19T12:56:51-05:00 2023-12-31 Everest Ito Group LLP 466 Foothill Blvd Suite 407 La Canada Flintridge CA 91011 990PF 2023-01-01 981178339 EFC Europe Foundation % MARXER & PARTNER ATTORNEYS EFCE 4232358265 Heiligkreuz 6 Vaduz LS 9490 Markus Summer Foundation Council 4232358265 2024-10-31 true true Dennis Ito P00541120 8187162701 2023 2025-03-06 01:10:19Z X X X X 132099476 X 0 X 201312 15925432 280428 16407172 0 0 112439 0 0 0 10134 0 0 0 242753 890 19743 39318 425277 0 0 0 0 0 425277 0 0 0 15981895 0 1208395 57592 57592 109065741 130826905 130826905 0 0 1214979 1214979 1214979 1214979 0 0 111489115 132099476 132099476 101660 152409 0 101660 152409 X 30012 30012 88634468 88634468 22664576 43282587 111329056 131947067 111430716 132099476 111329056 15981895 5614966 132925917 978850 131947067 0 0 0 0 0 0 false false false false false true true false true 0 false false false false false MARXER & PARTNER ATTORNEYS 4232358265 Heiligkreuz 6 Vaduz LS 9490 true false false false true false false false false false false false false false false false false false false false false Igor Czernecki 19 ALEXANDER STREET LONDON UK W2 5NT Foundation Council 0 0 0 0 Dr Markus Summer HEILIGKREUZ 6 VADUZ LS 9490 Foundation Council 0 0 0 0 Andrzej Czernecki 900 Brickell Key Blvd APT 2602 Miami FL 33131 Foundation Council 0 0 0 0 Admintrust Services AG STADTLE 31 VADUZ LS 9490 Foundation Council 0 0 0 39318 Cambridge Associates Ltd 80 VICTORIA STREET CARDINAL PLACE LONDON UK SW1E 5JL Advisory 242753 VARIOUS DONATIONS TO EDUCATIONAL FOUNDATIONS 978850 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 2021 2020 2019 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 X 24 201312 24 15925432 OTHER 24 280428 16407172 16407172 false false false false false false false false false false VARIOUS ACCOUNTING FEES 10134 REAL ESTATE 1214979 L Form 990-PF Page 1 Line Item D2 Form 990-PF Page 1 Line Item D2 85% Test under Treas. Reg. Sec. 53.4948-1(b): The foundation received the following support as defined under IRC Section 509(d), other than IRC Section 509(d)(4), since the date of its creation from: - Sources outside the United States ........ $88,664,855 - Sources within the United States ......... NONE - In total ................................. $88,664,855 Percentage of the total support received from sources outside the United States .............. 100% Therefore, since the percentage above is at least 85% of the total support, the foundation meets the 85% test under Treas. Reg. Sec. 53.4948-1(b). VARIOUS BONDS 0 INVESTMENT PORTFOLIOS 130702018 130702018 INVESTMENT ENTITIES 124887 124887 REAL ESTATE 1214979 1214979 1214979 LEGAL FEES 112439 DIVIDENDS RECEIVABLE 0 0 DISTRIBUTIONS FOR CHARITABLE PURPOSES 978850 BANK CHARGES REIMBURSEMENT EXPENSES 39318 Other income 5122 currency gain/loss 275306 FOREIGN CURRENCY ADJUSTMENT 5614966 BANK LOAN 0 VARIOUS PROFESSIONAL FEES 242753 As provided in IRC section 6651(a)(1) the penalty for late filing of a tax return shall not apply where the taxpayer can show that the failure to file timely was due to reasonable cause. We believe that the below described situation shows that the late filing was due to reasonable cause and that the penalty for late filing should not be applied. The initial e-filing submission was made prior to the extended due date of November 15, 2025. That e-filing was rejected, and the tax preparer immediately contacted the tax preparation software provider and the IRS and followed several suggestions to resolve the rejections with no success. We understand that the tax return was rejecting due to the fact that the IRS does not show this foreign entity as a tax-exempt organization within their system, so the electronic processing of Forms 990-PF and 990-T was not possible without some special handling. This identical e-filing rejection has been experienced for the past several years and each time the record was manually modified so that the e-filing could be completed. The taxpayer was told that the problem would be resolved for the 2023 tax year filing, but apparently the issue was not resolved. The last conversation with the IRS in late December indicated that the IRS "tax law group" would need to speak with a direct representative of the foreign foundation. Due to the holiday season and the Southern California fires which on January 8, 2025, destroyed the home of the tax representative on the client's Power of Attorney, a follow-up call was not made until February 11, 2025. Finally at that date, the matter was referred to the e-file help desk and resolution received on February 19, 2025. For the facts and circumstances described above, we believe that the late filing was due to reasonable cause and that the penalty for late filing should not be assessed. VAT TAXES