IRS Written Determinations
Free IRS private letter rulings, technical advice memoranda, and Chief Counsel advice with plain-English summaries and the official IRS release on every page.
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Foundation's university scholarship procedures receive advance approval
A private foundation proposed scholarships for qualifying members of a university chapter who needed tuition assistance. An independent selection committee would consider academic standing,…
Private foundation division approved with pass-through conditions
A family private foundation proposed transferring 40 percent of its assets equally to two new private foundations so different family branches could pursue separate charitable priorities. The IRS…
Three scholarship programs receive advance approval
A private foundation requested advance approval for the procedures used by three scholarship programs. The programs generally support qualifying students, many of whom are pursuing teaching degrees,…
Employee-child scholarship procedures receive advance approval
A private foundation requested advance approval for scholarships benefiting dependent children of a company's full-time employees. An independent nonprofit selection committee would evaluate…
Environmental research grant procedures receive advance approval
A private foundation requested advance approval for grants supporting research into sustainable and environmentally friendly ranching, forestry, and farming practices. Staff would identify qualified…
Employee scholarship procedures receive advance approval
A private foundation proposed scholarships for store-level employees of a related organization who were pursuing college degrees. Eligible employees needed at least one year of service, specified…
Foundation's campus construction set-aside is approved
A private foundation requested approval to set aside funds toward construction of a campus for a tax-exempt college and the surrounding community in an economically depressed area. The multiyear…
Humanities fellowship grant procedures are approved
A private foundation proposed a fellowship program supporting humanities scholars who create public-facing projects such as books, documentaries, curricula, and educational websites. Participating…
Private foundation split receives favorable tax rulings
A private foundation whose directors disagreed about how to carry out its mission proposed transferring half of its cash and publicly traded securities to a second private foundation. The IRS ruled…
Medical research grant procedures receive advance approval
A private foundation proposed grants to researchers at universities, hospitals, and research centers for work on heart disease, cancer, AIDS, and similar diseases. The program would be publicized…
Revised employee scholarship procedures receive approval
A private foundation revised an existing scholarship program for dependent children of a related employer's full-time employees. Nonrenewable awards would pay qualified tuition, fees, books, and…
Private foundation may receive most of a related foundation's assets
A private foundation asked about receiving approximately 78 percent of another private foundation's net assets after the transferor's directors disagreed about how to carry out its charitable…
Foundation may transfer most assets subject to distribution safeguards
A private foundation proposed transferring approximately 78 percent of its net assets to another commonly controlled private foundation while continuing its own charitable work with the remaining…
Foundation may buy out partners in low-income housing LLC
A private foundation that managed an affordable-housing LLC proposed buying the interests of the LLC's investor and special members, leaving the foundation as sole owner. The IRS ruled that the…
IRS approves scholarship program for low-income urban students
A private foundation proposed a scholarship program for low-income graduates from specified counties who planned to attend accredited four-year colleges or universities. Applicants had to meet…
Foundation's grants to artists and teachers approved
A private foundation requested advance approval for a grant program serving artists and teachers in a metropolitan area. Applicants would be evaluated on financial need, prior achievement,…
Foundation scholarship procedures approved
A private foundation requested advance approval for scholarships supporting needy undergraduate and graduate students in a metropolitan area. Its board would select recipients based on financial…
Graduate educational travel grants approved
A private foundation proposed expanding an existing graduate fellowship program to fund educational travel in the United States and abroad. Applicants would submit travel plans and educational…
Artist development grant program approved
A private foundation proposed a program providing artists with grants and industry resources for research, retreats, drafting, workshops, short works, and other professional development. Candidates…
Dental scholarship procedures approved
A private foundation requested advance approval for scholarships supporting students in dental assistant training and other dental professions. Applicants would be evaluated using financial need,…
Scholarship, travel, and internship grant procedures approved
A private foundation requested advance approval for scholarships to graduates of one state's high schools who attend any of three specified universities. The scholarships were renewable for up to…
Advanced doctoral scholarship procedures approved
A private foundation proposed one scholarship per academic year for a student pursuing an advanced doctoral degree at a specified university in a redacted academic field. Applicants had to be…
Scholarship procedures receive advance approval
A private foundation proposed scholarships for high-potential, low-income students attending college-preparatory high schools or colleges. Selection would consider financial need and academic…
Healthcare graduate scholarship procedures are approved
A private foundation proposed up to three annual scholarships for students within two semesters of completing graduate study in a healthcare-related field at selected universities. Selection…
Employer-related scholarship procedures approved
A tax-exempt private foundation asked the IRS to approve procedures for scholarships benefiting children of employees in specified divisions of an employer. An independent committee would select…
Sabbatical grant procedures approved for a private foundation
A private foundation requested advance approval of procedures for a grant program supporting sabbaticals for chief executives of charitable organizations. The grants would fund the executives’…
STEM and economics scholarship procedures approved
A private foundation proposed renewable scholarships for financially needy, high-achieving students pursuing degrees in economics or STEM fields. An independent selection committee would rank…
Computer-programming scholarship procedures approved
A private foundation proposed scholarships for students taking accelerated computer-programming immersion courses. The grants would cover portions of tuition, room, and board, with recipients…
Scholarship procedures for nontraditional students approved
A private foundation proposed scholarships for traditional and nontraditional students, including participants in registered apprenticeship programs. Applicants would be evaluated on their education…
Foundation may fund postgraduate scholarships for college athletes
A private foundation proposed one-year postgraduate scholarships for graduating male and female athletes in selected non-revenue college sports. Candidates would be evaluated on academic…
Religious-tolerance internship grant procedures approved
A private foundation proposed grants for college and graduate students taking unpaid or low-paying internships with nonprofits working to reduce religious intolerance and hate crimes. Applicants had…
Scholarship procedures receive advance approval
A private foundation proposed scholarships for residents seeking education or training for jobs in their region's visitor industry. Its board would select recipients using the proposed training…
Trade-program scholarship procedures approved
A private foundation proposed scholarships for trade-program students to buy required equipment, tools, materials, or testing. A committee of former educators and community members would use…
Renewable scholarship procedures approved
A private foundation proposed scholarships for qualifying undergraduate, graduate, and professional students, with renewals available for up to four years. Eligibility depended on citizenship,…
Former-employee scholarship procedures approved
A private foundation proposed scholarships for certain former company employees, their spouses, and their descendants. Applicants had to attend an eligible educational institution, show financial…
Need-based high school scholarships approved
A private foundation proposed need-based scholarships for graduates of a specified public Title I high school. A committee of foundation leaders and school principals would rank applicants using…
Scholarship procedures received advance approval
A private foundation proposed scholarships for qualifying high school seniors, including but not limited to children of employees of two companies. An independent committee would select recipients…
Multi-year educational website set-aside approved
A private foundation planned a multi-year educational website addressing global scientific and policy issues. It requested approval to set aside a redacted amount because immediate payment would not…
Musical education grant and instrument-loan procedures approved
A private foundation proposed a program supporting young classical-music students with instrument loans, paid instruction, ensemble scholarships, supplies, performance opportunities, and related…
Culinary training grant procedures received advance approval
A private foundation proposed grants that would let experienced young culinary professionals train at selected restaurants under mentors. Applicants would be evaluated using work experience, essays,…
Employer-related scholarship procedures received approval
A private foundation proposed scholarships for children and grandchildren of a company's employees to attend colleges, trade schools, vocational programs, or certificate programs. An independent…
Research and language-study grant procedures approved
A private foundation proposed two programs supporting study in a foreign country. One was a one-year fellowship for U.S. doctoral students conducting dissertation research, selected for academic…
Independently administered employee-child scholarships approved
A private foundation proposed scholarships for dependent children of longer-serving full-time employees of a company. A separate public charity would administer the program, receive applications…
Community-leadership scholarship procedures approved
A private foundation proposed need-based scholarships for students attending colleges, universities, or trade programs in one state. Selection emphasized community involvement and financial need…
Historic-house restoration set-aside received approval
A private foundation sought to set aside a matching grant for a public charity restoring a historic house listed as a National Historic Landmark. The recipient had to raise the remaining project…
Historic-building restoration set-aside approved
A private foundation proposed setting aside funds for a matching grant to a public charity restoring a culturally and historically significant building. The grant would fund part of the roof and…
Organization qualified under section 4945(f)
An existing section 501(c)(3) public charity asked to be recognized as an organization described in section 4945(f). Based on the information supplied and the organization’s stated future…
Scholarship and ministry loan-repayment procedures approved
A private foundation proposed scholarships for full-time theological students and loan-repayment grants for graduates working in ministry. Applicants had to attend or have graduated from a…
Scholarship and mentoring procedures approved
A private foundation proposed a scholarship program for students who met residency, academic, financial-need, recommendation, mentoring, and conduct requirements. Scholarship funds would go directly…
Early-childhood school set-aside approved
A private operating foundation planned a new early-childhood school in an economically disadvantaged neighborhood. The project included construction, staffing, initial operating deficits, tuition…
Employer-related scholarship procedures receive advance approval
A private foundation proposed scholarships for full-time employees of two related companies and for eligible dependent children of those employees. Officers, directors, and their children were…
Random-drawing scholarship procedures receive advance approval
A private foundation proposed one-year scholarships for children of a company's full-time employees. Applicants had to meet age, enrollment, and grade-point requirements, while children of officers…
Apprenticeship scholarship procedures receive advance approval
A private foundation proposed merit scholarships for lower-income teenagers participating in an apprenticeship program run through charitable organizations. Applicants had to complete the program,…
Foundation's revised scholarship procedures receive advance approval
A private foundation revised a scholarship program after its partner's afterschool program transitioned to a public charter school. Scholarships would cover demonstrated gaps in post-secondary…
Foundation's scholarly residency procedures receive advance approval
A private foundation proposed offering noncash scholarly residencies at a house it owned. Scholars, professionals, and others working in environmental science, conservation, education, or cultural…
Foundation's individual project-grant procedures receive advance approval
A private foundation proposed grants to accomplished or promising scholars and practitioners for travel, study, and projects supporting its charitable priorities. Grant opportunities would be…
Foundation's high-school and college scholarship procedures receive approval
A private foundation proposed need-based scholarships for graduating high-school students and current or prospective college and graduate students in one state. Applicants had to meet academic,…
Foundation receives extension for corpus-distribution elections
A private nonoperating foundation received most of its annual funding from another private foundation and needed to use prior excess qualifying distributions to satisfy redistribution obligations.…
Disease-awareness scholarship procedures approved
A private foundation requested advance approval for scholarships intended to increase awareness of a debilitating disease that can be difficult to diagnose. Eligible post-secondary students would…
Two-tier local scholarship program received advance approval
A private foundation proposed two scholarships for students from one redacted high school. One award served graduating students or recent graduates entering college or technical education, while the…
What these documents are
- Private letter rulings (PLRs): A taxpayer asked the IRS to rule on a planned transaction before doing it. The ruling shows exactly how the IRS applied the Code to those facts.
- Technical advice memoranda (TAMs): The IRS National Office answering a question raised during an audit or other proceeding.
- Chief Counsel advice (CCAs): IRS lawyers advising their own field staff on how to apply the law.
- Determination letters: Rulings on exempt-organization matters, such as whether an organization qualifies under § 501(c)(3) or a foundation's grant procedures pass § 4945.
- Not precedent, still useful: Under 26 U.S.C. § 6110(k)(3) none of these can be cited as precedent. They remain the best public window into how the IRS actually rules on facts like yours, and practitioners read them for exactly that.