2025-02-12T12:14:08-06:00 2024-03-31 450250958 EIDE BAILLY LLP 200 W MERCER ST STE E300 SEATTLE WA 981193958 990PF 2023-04-01 981227742 GLENORCHY MARKETPLACE FOUNDATION GLEN 2065790702 11100 NE 8TH STREET SUITE 400 BELLEVUE WA 98004 KRISTA SEYMOUR TREASURER 2065790702 2025-02-11 1 0 COLLEEN C LOUGHRAN CPA P00286018 2062857242 2025-02-11 2023 2025-03-06 01:10:19Z X 35068131 X 1123083 836 836 836 0 0 163326 163326 1123919 836 836 0 0 0 0 1473 0 0 1473 18380 6000 6000 12380 21881 0 0 21881 1223 0 0 1223 869 0 0 15160 43826 6000 6000 52117 1533285 1533285 1577111 6000 6000 1585402 -453192 0 0 201319 142920 142920 42359 7317 7317 35291936 34925211 34925211 35535614 35068131 35068131 14291 14291 0 X 35521323 35068131 0 0 0 0 35521323 35068131 35535614 35068131 35521323 -453192 0 35068131 0 35068131 0 0 0 0 0 6060 0 0 0 6060 0 6060 6060 0 0 0 0 0 0 0 0 0 0 0 1 1 WA 1 1 0 1 0 1 N/A PAUL BRAINERD 2065790702 11100 NE 8TH STREET STE 400 BELLEVUE WA 98004 1 NZ 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 PAUL BRAINERD 11100 NE 8TH STREET STE 400 BELLEVUE WA 98004 PRESIDENT / DIRECTOR 5.00 0 0 0 DEBORAH BRAINERD 11100 NE 8TH STREET STE 400 BELLEVUE WA 98004 VICE PRESIDENT / DIRECTOR 2.50 0 0 0 KRISTA SEYMOUR 11100 NE 8TH STREET STE 400 BELLEVUE WA 98004 SECRETARY / TREASURER 1.50 0 0 0 NONE 0 NONE 0 SUSTAINABLE COMMUNITY DEVELOPMENT IN GLENORCHY, NEW ZEALAND. PROJECT INCLUDES COMMUNITY STORE, PUBLIC CAMPGROUND, RESTORATION OF NATIVE LANDSCAPE, EDUCATING PUBLIC ON SUSTAINABLE PRACTICES. THE CHARITABLE ACTIVITY IS CONDUCTED BY THE FOUNDATION THROUGH ITS FUNCTIONALLY RELATED BUSINESS, THE HEADWATERS LIMITED, A WHOLLY OWNED NEW ZEALAND CORPORATION, THAT IS FUNDED BY GLENORCHY MARKETPLACE FOUNDATION. 1585402 0 0 248420 0 248420 0 0 248420 3726 244694 12235 X 1585402 0 0 1585402 X 0 0 0 11158 11158 0 0 0 9484 9484 1585402 3018312 3022110 1574491 9200315 1533285 0 0 0 1533285 52117 3018312 3022110 1574491 7667030 0 0 8157 32957 46645 72026 159785 0 0 0 0 PAUL BRAINERD DEBORAH BRAINERD X THE HEADWATERS LIMITED MACTODD LEVEL 3 11-17 CHURCH STREET QUEENSTOWN NZ 9300 NC SUSTAINABLE COMMUNITY DEVELOPMENT IN GLENORCHY, NEW ZEALAND. PROJECT INCLUDES COMMUNITY STORE, PUBLIC CAMPGROUND, RESTORATION OF NATIVE LANDSCAPE, EDUCATING PUBLIC ON SUSTAINABLE PRACTICES.GLENORCHY MARKETPLACE FOUNDATION'S CHARITABLE ACTIVITY IS CONDUCTED BY THE FOUNDATION THROUGH ITS WHOLLY-OWNED FUNCTIONALLY-RELATED BUSINESS ACTIVITY, THE HEADWATERS LIMITED.OPERATING A SUSTAINABLE COMMUNITY DEVELOPMENT IS THE PRIMARY MEANS BY WHICH THE FOUNDATION ACCOMPLISHES ITS CHARITABLE AND EDUCATIONAL PURPOSES. 1533285 1533285 0 14 836 0 836 0 836 0 0 0 0 0 0 0 0 0 0 X X 1 PAUL AND DEBORAH BRAINERD 11100 NE 8TH STREET STE 400 BELLEVUE WA 98004 1123083 X ACCOUNTING FEES 18380 6000 6000 12380 DEPRECIATION 990-PF, PART I, LINE 19 DEPRECIATION SCHEDULE IS AVAILABLE UPON REQUEST INVENTORY AT BEGINNING OF YEAR 990-PF, PART I, LINE 10 THE INVENTORY AT END OF YEAR REPORTED ON THE PRIOR YEAR INCOME AND COST OF GOODS SOLD STATEMENT WAS $241,708 USD.THE INVENTORY AT BEGINNING OF YEAR REPORTED ON THE CURRENT YEAR INCOME AND COST OF GOODS SOLD STATEMENT IS $42,359 USD.THE DIFFERENCE IS DUE TO INVENTORY HELD BY THE GLENORCHY MARKETPLACE IN NEW ZEALAND BEING PURCHASED BY AND TRANSFERRED TO THE HEADWATERS LIMITED, A FUNCTIONALLY RELATED BUSINESS, ON MARCH 31, 2023. STATEMENT PURSUANT TO SECTION 1.351-3(A) 926, PARTS I-IV STATEMENT PURSUANT TO SECTION 1.351-3(A) BY GLENORCHY MARKETPLACE FOUNDATION EIN:98-1227742A SIGNIFICANT TRANSFEROR1) THE NAME AND EMPLOYER IDENTIFICATION NUMBER (IF ANY) OF THE TRANSFEREE CORPORATION: THE HEADWATERS LIMITED EIN: 02) THE DATE(S) OF THE TRANSFER(S) OF ASSETS: 12/31/20233) THE AGGREGATE FAIR MARKET VALUE AND BASIS, DETERMINED IMMEDIATELY BEFORE THE EXCHANGE, OF THE PROPERTY TRANSFERRED BY SUCH TRANSFEROR IN THE EXCHANGE:(I) IMPORTATION PROPERTY TRANSFERRED IN A LOSS IMPORTATION TRANSACTION, AS DEFINED IN SECTION 1.362(C)(2)AND (3), RESPECTIVELY;FAIR MARKET VALUE: N/ABASIS: N/A(II) LOSS DUPLICATION PROPERTY AS DEFINED IN SECTION 1.3624(G)(1);FAIR MARKET VALUE: N/ABASIS: N/A(III) PROPERTY WITH RESPECT TO WHICH ANY GAIN OR LOSS WAS RECOGNIZED ON THE TRANSFER (WITHOUT REGARD TO WHETHER SUCH PROPERTY IS ALSO IDENITIFED IN PARAGRAPH (A)(3)(I) OR (II) OF THIS SECTION);FAIR MARKET VALUE: N/ABASIS: N/A(IV) PROPERTY NOT DESCRIBED IN PARAGRAPH (A)(3)(I), (II), OR (III) OF THIS SECTION.FAIR MARKET VALUE: $ 1 ,849,135BASIS: $ 1 ,849,1354) THE DATE AND CONTROL NUMBER OF ANY PRIVATE LETTER RULING(S) ISSUED BY THE INTERNAL REVENUE SERVICE IN CONNECTION WITH THE 351 EXCHANGE:NO PRIVATE LETTER RULINGS WERE ISSUED WITH RESPECT TO THE SECTION 351 EXCHANGE STATEMENT FILED PURSUANT TO SECTIONS 1.6038B-1(C) AND 1.6038B-1T(C) 926, PARTS I-IV 1) NAME OF U.S. TRANSFEROR: GLENORCHY MARKETPLACE FOUNDATION EIN: 98-1227742ADDRESS: 11100 NE 8TH STREET, SUITE 400BELLEVUE, WA 980042) NAME OF FOREIGN TRANSFEREE: THE HEADWATERS LIMITED EIN:ADDRESS: MACTODD, LEVEL 3, 11-17 CHURCH STREETQUEENSTOWN, 9300 NEW ZEALANDCOUNTRY OF INCORPORATION: NEW ZEALAND3) THE FOLLOWING CONSIDERATION WAS RECEIVED BY THE U.S. TRANSFEROR: $ -4) THE FOLLOWING PROPERTY WAS TRANSFERRED BY THE U.S. TRANSFEROR TO THE FOREIGN TRANSFEREE:(I) ACTIVE TRADE OR BUSINESS PROPERTY: NOT APPLICABLE(II) STOCK OR SECURITIES: NOT APPLICABLE(III) DEPRECIATED PROPERTY: NOT APPLICABLE (IV) PROPERTY TO BE LEASED: NOT APPLICABLE(V) PROPERTY TO BE SOLD: NOT APPLICABLE(VI) TRANSFERS TO FSCS: NOT APPLICABLE (VII) TAINTED PROPERTY: NOT APPLICABLE(VIII) FOREIGN LOSS BRANCH: NOT APPLICABLE (IX) OTHER INTANGIBLES: NOT APPLICABLE 5) THE FOLLOWING PROPERTY OF A FOREIGN BRANCH WITH PREVIOUSLY DEDUCTED LOSSES SUBJECT TO THE RULES OF 1.367(A)-6T WAS TRANSFERRED BY THE U.S. TRANSFEROR TO THE FOREIGN TRANSFEREE:NOT APPLICABLE(6) THE TRANSFER OF PROPERTY BY THE U.S. TRANSFEROR TO THE U.S. TRANSFEREE IS AN EXCHANGE DESCRIBED IN SECTION 361(A). THE CONDITIONS SET FORTH IN THE SECOND SENTENCE OF SECTION 367(A)(5), AND ANY REGULATIONS UNDER THAT SECTION, HAVE BEEN SATISFIED. THE FOLLOWING ADJUSTMENTS TO BASIS, OR OTHER ADJUSTMENTS, HAVE BEEN MADE TO THE PROPERTY TRANSFERRED:NOT APPLICABLE LEGAL FEES 1473 0 0 1473 NOTE FROM THE HEADWATERS LIMITED - FUNCTIONALLY RELATED BUSINESS 11405618 11038893 11038893 THE HEADWATERS LIMITED STOCK - FUNCTIONALLY RELATED BUSINESS 23886318 23886318 23886318 BANK FEES 357 0 0 357 OFFICE EXPENSES 512 0 0 512 ACCRUED TO CASH ADJUSTMENT PRIOR YEAR REVERSAL 0 0 0 14291 CONTRACTORS 21881 0 0 21881 STATE EXCISE TAX 1223 0 0 1223 THE HEADWATERS LIMITED (FKA POUNAMU HOLDINGS 2014 LTD) MACTODD LEVEL 3 11-17 CHURCH STREET QUEENSTOWN NZ 9300 000000000 NOTE RECEIVABLE FROM THE HEADWATERS LIMITED, CONVERTED TO A DONATION 1533285 366725 THE HEADWATERS LIMITED (FKA POUNAMU HOLDINGS 2014 LTD) MACTODD LEVEL 3 11-17 CHURCH STREET QUEENSTOWN NZ 9300 000000000 DONATION AMOUNT TRANSFERRED TO THE HEADWATERS LIMITED 1533285 1533285