SecProbe.io

April 15, 2011
 Via E-mail

Ms. Candace S. Cummings, Vice Presiden t-Administration and General Counsel
V. F. Corporation 105 Corporate Center Boulevard Greensboro, North Carolina 27408
Re: V.F. Corporation
 Form 10-K for Fiscal Year Ended January 1, 2011
Filed March 2, 2011 File No. 001-05256

Dear Ms. Cummings:
 We have reviewed your filing and have the following comments.  In some of our
comments, we may ask you to provide us with  information so we may better understand your
disclosure.
 Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
 After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.

Form 10-K for Fiscal Year Ended January 1, 2011

 Item 7.  Management’s Discussion and Analys is of Financial Condition and Results of
Operations, page 27
 Analysis of Results of Operations, page 28

 Consolidated Statements of Income, page 28

1. We note your disclosures indicati ng that the declines in your e ffective income tax rates in
2010 from 2009 and in 2009 from 2008 were pr imarily attributable to growth in your
international businesses in jurisdictions having effective income tax rates that are substantially lower than rates in the United States.  We further note from remarks with
respect to your international operations by Mr. Bob Shearer, Chief Financial Officer,
during your March 11, 2011 analyst meeting that  “…a 15% effective tax rate is a great
plus to an already superior model.”  In fu ture filings, please quan tify your international
effective tax rate and compare such rate with your U.S. effective tax rate.

Candace S. Cummings V.F. Corporation April 15, 2011 Page 2

 2. With a view towards discussion and analysis in  future filings, please tell us the specific
countries where earnings are generated that  benefited from the lower international
effective tax rate, and explai n if recent uncertainty in economic conditions in such
countries may result in material increases to  the effective tax rate s you have historically
experienced.  See Item 303(a)(3)(i) of Regul ation S-K and Section III.B of SEC Release
33-8350.
  Liquidity and Cash Flows, page 37

3. We note your disclosure at page F-32 i ndicating that you have not provided deferred
taxes on $1,002 million of undistributed earnings from certain international subsidiaries
where the earnings are considered to be perm anently reinvested.  With a view towards
discussion and analysis in future filings, pl ease tell us the amounts of investments held by
foreign subsidiaries that would be subj ect to a significant tax effect upon their
repatriation.  In this respect, the discussion w ould illustrate that some investments are not
potentially available to fund domestic opera tions without paying a significant amount of
taxes upon their repatriation.
 Note P – Income Taxes, page F-31

4. We note on page F-32 that you have not provided deferred taxes on $1,002 million of
undistributed earnings from certa in international subsidiari es where the earnings are
considered to be permanently reinvested.  In future filings, please disclose the unrecognized deferred tax liability related to your investments in  foreign subsidiaries that
are essentially permanent in duratio n, pursuant to ASC 740-30-50-2c.
 Exhibits

5. We note that exhibits 10(Z) and (AA) app ear to be missing exhibits, schedules or
attachments.  Please confirm that you will file th ese exhibits in their entirety as required
by Item 601(b)(10) of Regulation S- K with your next periodic report.
  We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

Candace S. Cummings V.F. Corporation April 15, 2011 Page 2

 In responding to our comments, please provi de a written statement from the company
acknowledging that:
• the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;

• staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

• the company may not assert staff comments as  a defense in any proceeding initiated by
the Commission or any person under the federa l securities laws of  the United States.

You may contact David Walz at (202) 551- 3358 or Ryan Milne at (202) 551-3688 if you
have questions regarding comments on the financ ial statements and related matters.  Please
contact Erin Wilson at (202) 551-6047 or David Link at (202) 551-3356 with any other
questions.
Sincerely,
   /s/ David Link for     John Reynolds
Assistant Director