2026-07-23T13:45:58-05:00 2024-06-30 390859910 BAKER TILLY ADVISORY GROUP LP 790 N WATER ST SUITE 2000 MILWAUKEE WI 53202 990 2023-07-01 237074729 FRIENDS OF THE INTERNATIONAL INSTITUTE OF WISCONSIN INC FRIE 4142256220 1110 N DR MARTIN LUTHER KING JR 4 MILWAUKEE WI 53203 PAULINE KLAFFENBOECK CHAIRWOMAN 4142256220 2026-07-23 1 1 SHELBY NETZ P01405265 4147775500 2026-07-23 2023 2025-03-06 01:10:19Z PAULINE KLAFFENBOECK 1110 N DR MARTIN LUTHER KING JR 420 MILWAUKEE WI 53203 2121949 0 X IIWISCONSIN.ORG X 1988 WI ORGANIZATION DEDICATED TO PROMOTING THE INTERNATIONAL INSTITUTE OF WISCONSIN IN ITS EFFORTS TO PROMOTE INTERNATIONAL COOPERATION, UNDERSTANDING, AND A MULTI-ETHNIC, MULTI-CULTURAL PERSPECTIVE. 6 4 0 6 -7921 0 0 0 0 0 205058 333291 0 0 205058 333291 60000 120000 0 0 0 0 0 0 0 25441 6039 85441 126039 119617 207252 8137715 8901223 20000 20000 8117715 8881223 ORGANIZATION DEDICATED TO THE PROMOTION OF INTERNATIONAL COOPERATION, UNDERSTANDING, AND A MULTI-ETHNIC, MULTI CULTURAL PERSPECTIVE THROUGH EDUCATION, EXCHANGE, COMMUNICATION, SOCIAL ACTIVITIES, ARTS AND IMMIGRATION, AND NATURALIZATION SERVICES. 0 0 120000 120000 CONTRIBUTIONS TO THE INTERNATIONAL INSTITUTE OF WISCONSIN. 120000 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1 0 0 0 1 0 0 0 1 1 0 0 0 0 0 0 0 0 0 0 0 X 6 4 0 0 0 0 0 0 0 1 1 0 0 1 1 0 0 0 1 0 0 0 X PAUL TREBIAN 4142256220 1110 N DR MARTIN LUTHER KING JR 420 MILWAUKEE WI 53203 PAULINE KLAFFENBOECK CHAIRWOMAN 1.00 X X 0 0 0 DAVID CARTER TREASURER 1.00 X X 0 0 0 DONNA ROEBER ASSISTANT TREASURER 1.00 1.00 X X 0 0 0 ESTELA VAZQUEZ-ORNELAS SECRETARY 10.00 45.00 X X 0 52229 0 PAUL TREBIAN BOARD MEMBER AND IIW PRESIDENT/CEO 1.00 70.00 X 0 102917 0 KELLY JORDAN BOARD MEMBER 1.00 1.00 X 0 0 0 0 155146 0 0 0 0 0 0 315192 -7921 323113 1806757 1788658 18099 18099 18099 333291 0 -7921 341212 120000 120000 FOREIGN TAXES 5929 5929 MISCELLANEOUS 110 110 126039 120000 6039 0 15555 15560 79377 224041 8042783 8661622 8137715 8901223 20000 20000 20000 20000 X 8026183 8766189 91532 115034 8117715 8881223 8137715 8901223 207252 556256 0 X 0 0 0 X X 1 INTERNATIONAL INSTITUTE OF WISCONSIN 390806350 7 1 120000 0 1 120000 0 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1 1 1 0 0 0 0 245553 0 245553 0 0 0 0 0 0 0 245553 0 7509826 0 415269 0 0 0 7925095 0 0 0 0 7925095 0 118876 0 7806219 0 273218 0 0 0 273218 0 245553 208720 273218 273218 0 273218 120000 0 0 0 0 0 120000 120000 273218 43.920000000000 273218 873454 0 0 0 0 0 0 0 0 0 0 120000 120000 0 753454 273218 0 0 0 0 0 0 SCHEDULE A, PART V, SECTION E, LINES 2 AND 5: REASONABLE CAUSE STATEMENT: FAILURE TO MEET SECTION 509(A)(3) DISTRIBUTION REQUIREMENT TAXPAYER NAME: FRIENDS OF THE INTERNATIONAL INSTITUTE OF WISCONSIN, INC. THE ABOVE-NAMED ORGANIZATION IS A TAX-EXEMPT ORGANIZATION ESTABLISHED UNDER INTERNAL REVENUE CODE SECTION 509(A)(3) THAT SUPPORTS ANOTHER SPECIFIC 501(C)(3) PUBLIC CHARITY, INTERNATIONAL INSTITUTE OF WISCONSIN, INC. ("SUPPORTED ORGANIZATION") FINANCIALLY BY MAKING ANNUAL DISTRIBUTIONS TO THE SUPPORTED ORGANIZATION. THE MISSION OF THE ORGANIZATION IS TO PROMOTE THE SUPPORTED ORGANIZATION IN ITS EFFORTS FOR INTERNATIONAL COOPERATION, UNDERSTANDING, AND A MULTI-ETHNIC, MULTI-CULTURAL PERSPECTIVE THROUGH EDUCATION, EXCHANGE, COMMUNICATION, SOCIAL ACTIVITIES, ARTS AND IMMIGRATION, AND NATURALIZATION SERVICES. FOR THE TAX YEAR ENDING JUNE 30, 2024, THE ORGANIZATION DID NOT MEET ITS DISTRIBUTION REQUIREMENTS BECAUSE THE ORGANIZATION WAS NOT ADVISED OF THIS REQUIREMENT. WHILE UNDERGOING A CHANGE IN ACCOUNTING FIRMS THROUGH THEIR ORDINARY CYCLE OF OPERATIONS, THE ORGANIZATION WAS INFORMED BY THEIR NEW FIRM THAT THEY HAD NOT BEEN MEETING THEIR ANNUAL DISTRIBUTION REQUIREMENTS AND SINCE THAT POINT, THE ORGANIZATION HAD TAKEN STEPS TO REMEDY THE SITUATION BY ENGAGING THE NEW ACCOUNTING FIRM AS WELL AS REPUTABLE LEGAL COUNSEL IN THE PROCESS OF COMPLETING THE FORM 990 FILING FOR THE JUNE 30, 2024. DISCUSSION: A TYPE III NON-FUNCTIONALLY INTEGRATED SUPPORTING ORGANIZATION ESTABLISHED UNDER SECTION 509(A)(3) IS REQUIRED TO DISTRIBUTE A MINIMUM OF 85% OF ITS ADJUSTED NET INCOME FOR THE PRECEDING TAX YEAR OR 3.5% OF THE FAIR MARKET VALUE OF NON-EXEMPT-USE ASSETS. SECTION 1.509(A)-4(I)(5)(II)(F) PROVIDES THAT A TYPE III SUPPORTING ORGANIZATION THAT FAILS TO MEET ITS DISTRIBUTION REQUIREMENT WILL NOT BE CLASSIFIED AS A PRIVATE FOUNDATION FOR THE TAXABLE YEAR IN WHICH IT FAILS TO MEET THE DISTRIBUTION REQUIREMENT WHEN THE ORGANIZATION ESTABLISHES THAT SUCH FAILURE WAS DUE TO: (1) UNFORESEEN EVENTS OR CIRCUMSTANCES THAT ARE BEYOND THE ORGANIZATION'S CONTROL, A CLERICAL ERROR, OR AN INCORRECT VALUATION OF ASSETS; (2) REASONABLE CAUSE AND NOT TO WILLFUL NEGLECT; AND (3) THE DISTRIBUTION REQUIREMENT IS MET WITHIN 180 DAYS AFTER THE ORGANIZATION DISCOVERED THE ERROR. THE CONCEPT OF REASONABLE CAUSE APPEARS THROUGHOUT THE PENALTY PROVISIONS OF THE INTERNAL REVENUE CODE. REASONABLE CAUSE, HOWEVER, IS NOT EXPLICITLY DEFINED IN THE CODE OR ITS UNDERLYING REGULATIONS. THE SUPREME COURT DESCRIBED REASONABLE CAUSE IN THE CONTEXT OF SECTION 6651 AS ORDINARY CARE AND PRUDENCE." UNITED STATES V. BOYLE, 469 U.S. 241, 246 (1985). IN CONTRAST, WILLFUL NEGLECT WAS DEFINED IN BOYLE AS "A CONSCIOUS, INTENTIONAL FAILURE OR RECKLESS INDIFFERENCE." 469 U.S. AT 245. THE UNITED STATES SUPREME COURT STATED IN BOYLE THAT: [W]HEN AN ACCOUNTANT OR ATTORNEY ADVISES A TAXPAYER ON A MATTER OF TAX LAW, SUCH AS WHETHER A LIABILITY EXISTS, IT IS REASONABLE FOR THE TAXPAYER TO RELY ON THAT ADVICE. MOST TAXPAYERS ARE NOT COMPETENT TO DISCERN ERROR IN THE SUBSTANTIVE ADVICE OF AN ACCOUNTANT OR ATTORNEY. TO REQUIRE THE TAXPAYER TO CHALLENGE THE ATTORNEY, TO SEEK A "SECOND OPINION, OR TO TRY TO MONITOR COUNSEL ON THE PROVISIONS OF THE CODE HIMSELF WOULD NULLIFY THE VERY PURPOSE OF SEEKING THE ADVICE OF A PRESUMED EXPERT IN THE FIRST PLACE. CITATION OMITTED. THE COURT EXPLAINED THAT A TAXPAYER CAN DEMONSTRATE REASONABLE CAUSE WHEN A TAXPAYER REASONABLY RELIES ON THEIR TAX PROFESSIONAL WHEN ALL NECESSARY AND ACCURATE INFORMATION IS PROVIDED TO DISCERN A COMPLEX TAX ISSUE. IN NEONATOLOGY ASSOCS., P.A., ET AL. V. COMM'R., 115 T.C. 43, AFF'D 299 F.3D 221 (3RD CIR. 2002), THE COURT ESTABLISHED A THREE-PRONG TEST WITH REGARD TO RELIANCE ON TAX ADVICE. THE TAXPAYER MUST PROVE BY A PREPONDERANCE OF THE EVIDENCE THAT THE TAXPAYER MEETS EACH REQUIREMENT OF THE FOLLOWING THREE-PRONG TEST: (1) THE ADVISER WAS A COMPETENT PROFESSIONAL WHO HAD SUFFICIENT EXPERTISE TO JUSTIFY RELIANCE, (2) THE TAXPAYER PROVIDED NECESSARY AND ACCURATE INFORMATION TO THE ADVISER, AND (3) THE TAXPAYER ACTUALLY RELIED IN GOOD FAITH ON THE ADVISER'S JUDGMENT. THE ORGANIZATION EXERCISED ORDINARY BUSINESS CARE AND PRUDENCE BY HIRING A REPUTABLE ACCOUNTING FIRM TO ASSIST WITH THEIR ANNUAL FORM 990 FILING FOR THE TAX YEAR IN QUESTION AND PROVIDE THE GUIDANCE NEEDED TO COMPLY WITH THE MINIMUM DISTRIBUTION REQUIREMENTS AS A TYPE III NON-FUNCTIONALLY INTEGRATED SUPPORTING ORGANIZATION. THE ORGANIZATION PROVIDED THE ACCOUNTING FIRM WITH ALL THE NECESSARY AND ACCURATE INFORMATION THAT WOULD HAVE PROMPTED THE ACCOUNTING FIRM TO NOTIFY THE ORGANIZATION OF THE DISTRIBUTION REQUIREMENT. LASTLY, THE ORGANIZATION RECOGNIZES THE COMPLEXITY OF ITS TAX COMPLIANCE AND SOUGHT ADVISORY SERVICES BECAUSE IT DOES NOT HAVE THE ADVISORY SERVICES WITHIN THE ORGANIZATION, AND IT DID ACTUALLY RELY IN GOOD FAITH ON THE ACCOUNTING FIRM'S JUDGMENT. ACCORDINGLY, THE ORGANIZATION CAN DEMONSTRATE REASONABLE CAUSE BECAUSE IT REASONABLY RELIED ON ITS TAX PROFESSIONAL THAT HAD ALL NECESSARY AND ACCURATE INFORMATION PROVIDED TO DISCERN THE COMPLEX TAX ISSUE OF ENSURING THE ORGANIZATION MET ITS DISTRIBUTION REQUIREMENT. THE ORGANIZATION INTENDS TO MAKE THE TRUE-UP DISTRIBUTION WITHIN ITS NEXT FISCAL YEAR ENDED JUNE 30, 2026. MOREOVER, THE ORGANIZATION RECOGNIZES THE IMPORTANCE OF THEIR TAX COMPLIANCE OBLIGATIONS AND HAS TAKEN STEPS TO ENSURE THIS DOES NOT OCCUR AGAIN. THE ORGANIZATION RESPECTFULLY REQUESTS LENIENCY ON THIS MATTER THROUGH THE ABATEMENT OF ANY PENALTIES DUE TO REASONABLE CAUSE STEMMING FROM A GOOD-FAITH EFFORT TO ENGAGE A KNOWLEDGEABLE AND PROFESSIONAL ACCOUNTING FIRM TO COMPLETE THEIR ANNUAL FORM 990. FINALLY, IF THE ORGANIZATION IS REQUIRED TO PAY IRS PENALTIES RESULTING FROM THIS OVERSIGHT, IT WILL BE VERY DETRIMENTAL TO FULFILLING THEIR TAX-EXEMPT MISSION TO PROMOTE THE SUPPORTED ORGANIZATION IN ITS EFFORTS FOR INTERNATIONAL COOPERATION, UNDERSTANDING, AND A MULTI-ETHNIC, MULTI-CULTURAL PERSPECTIVE THROUGH EDUCATION, EXCHANGE, COMMUNICATION, SOCIAL ACTIVITIES, ARTS AND IMMIGRATION, AND NATURALIZATION SERVICES. PART IV, SECTION D, LINE 3: THE ORGANIZATION AND ITS SUPPORTED ORGANIZATION SHARE COMMON BOARD MEMBERS WHO HAVE A SIGNIFICANT VOICE IN THE ORGANIZATION'S INVESTMENT POLICIES. 1 INTERNATIONAL INSTITUTE OF WISCONSIN INC 1110 N DR MARTIN LUTHER KING JR 420 MILWAUKEE WI 53203 390806350 501(C)(3) 120000 0 TO SUPPORT THE MISSION OF INTERNATIONAL INSTITUTE OF WISCONSIN, INC 1 0 PART I, LINE 2: MONTHLY REPORTS ARE PREPARED AND APPROVED BY THE PRESIDENT/CEO FOR GRANTS RECEIVED. THE APPROPRIATE INFORMTION IS REVIEWED BY AN OUTSIDE INDEPENDENT CONSULTANT. FORM 990, PART VI, SECTION B, LINE 11B THE 990 IS REVIEWED BY THE TREASURER AND THE EXECUTIVE COMMITTEE AND THEN GIVEN TO THE BOARD BEFORE FILING. FORM 990, PART VI, SECTION B, LINE 12 THE ORGANIZATION IS EVALUATING ITS CONFLICT OF INTEREST POLICY AND IN THE PROCESS OF MAKING UPDATES TO BE EFFECTIVE IN THE NEXT FISCAL YEAR. FORM 990, PART VI, SECTION C, LINE 19 THE DOCUMENTS ARE AVAILABLE UPON REQUEST. INTERNATIONAL INSTITUTE OF WISCONSIN INC 1110 N DR MARTIN LUTHER KING JR 420 MILWAUKEE WI 53203 390806350 IMMIGRATION ASSISTANCE WI 501(C)(3) LINE 7 N/A 0 0 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0