The College of William & Mary Foundation

“The foundation owns works of art for the benefit of the muscarelle museum of william & mary, as well as antiques used by william & mary in various buildings.”

“Payout from endowment funds is used for scholarships, professorships and other departmental uses, or for the general purposes of the foundation or william & mary. In addition to endowments reported in schedule d, the foundation has an irrevocable interest in a portion of the income from these entities. The value of the foundation's interest in these entities is reported as funds held in trust by others, and was $202,246,097 and $204,422,205 at june 30, 2023 and 2022, respectively. Change in the value of this interest during the year is $2,176,108. The foundation also holds certain endowments for the benefit of the omohundro institute of early american history and culture valued at $20,651,766 and $20,116,426 at june 30, 2023 and 2022, respectively. In accordance with accounting guidance, the omohundro endowments are reported with an offsetting liability and activity relating to the omohundro endowments is not reported in the foundation's statement of activity. As a result, the omohundro funds are not included in part v of schedule d. Distributions in the amount of $763,690 were made from the omohundro endowments to the omohundro institute during the year.”

“The Foundation, the 1693 Foundation and the Fund are nonstock corporations which have been determined by the Internal Revenue Service to be exempt from taxes on income derived from activities related to its exempt purpose under Section 501(c)(3) of the Internal Revenue Code. The REF is a stock corporation, wholly owned by the Foundation, which has been determined by the Internal Revenue Service to be exempt from taxes on income derived from activities related to its exempt purpose under Section 501(c)(2) of the Internal Revenue Code. Reliance is a limited liability company that is not disregarded for tax purposes, and therefore is subject to tax. CWMF Ventures, Foundation Services, 1693 Management and Brown Hall, LLC are disregarded entities for income tax purposes, and all activity is reported on the Foundation's tax return. ASC Topic 740, Income Taxes, provides guidance for how uncertain tax positions should be recognized, measured, presented, and disclosed in financial statements. ASC Topic 740 requires the evaluation of tax positions taken or expected to be taken in the course of preparing tax returns of the Foundation and its affiliated entities to determine whether the tax positions will "more-likely-than-not" be sustained by the applicable tax authority. As a result, tax positions not meeting the more-likely-than not threshold would result in a current year expense or the absence of a benefit, as appropriate for the tax position. The Foundation has concluded that no provision for income tax is required in the Foundation's consolidated financial statements for the years ended June 30, 2023 and 2022. As of June 30, 2022, the Foundation had federal net operating losses available for carryforward in the amount of $3,893,197 as a result of unrelated business taxable income ("UBTI") resulting from investments in the Trust. UBTI is taxed at the prevailing corporate tax rate. Reliance had a net operating loss carryforward of $281,455 as of June 30, 2022. The loss carryforwards begin to expire in 2027. Due to the uncertainty about whether these losses will result in a tax asset, no tax asset was recorded in the consolidated financial statements at June 30, 2023 and 2022. Net operating losses arising in tax years ending after December 31, 2017, have an indefinite carryforward period. Losses arising in earlier tax years have a carryforward period of twenty years. Losses arising in tax years beginning after December 31, 2017, are limited to 80% of taxable income in the year deducted. The filing deadline for the June 30, 2023, tax return is May 15, 2024. In addition to the year ended June 30, 2023, the years ended June 30, 2022, 2021, and 2020 are open for inspection by the taxing authorities.”