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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Two scholarship programs received advance approval
A private foundation operated two nonrenewable scholarship programs for students in a redacted state. One program served high school students entering four-year colleges, while the other served…
Summer camp scholarship procedures received advance approval
A private foundation proposed scholarships for high school juniors and seniors who completed a short summer camp about issues and careers in aging. Applicants also had to be United States citizens…
Scholarship grant procedures received advance approval
A nonexempt charitable trust that was also a private foundation requested advance approval of its scholarship procedures under section 4945(g). The program favored students of a redacted ancestry…
Social-venture fellowship procedures approved
A private foundation proposed an eight-month fellowship program to help young social entrepreneurs develop ventures through housing, office space, mentoring, business support, and coaching.…
Community college scholarship procedures receive advance approval
A private foundation proposed scholarships for local residents attending a community college. Eligible students had to live in the community, satisfy the college's admission standards, and enroll…
Community project grant procedures receive advance approval
A private foundation proposed grants to individuals for projects intended to improve distressed neighborhoods and develop creative, civic, educational, or professional skills. Projects had to be…
Foundation may set aside funds for a public garden expansion
A private foundation devoted to city beautification wanted to expand a public garden into an adjacent parking lot and relocate and rebuild a bandstand used for free concerts. The project required…
Scholarship and internship grant procedures receive advance approval
A private foundation proposed a four-year program for graduating high school seniors who were unlikely to receive enough assistance from conventional sources. Awards would supplement other financial…
Community college completion scholarship procedures receive approval
A private foundation proposed scholarships to help public community college students complete associate degrees and continue toward bachelor's degrees at four-year institutions. Eligibility depended…
Student internship grant procedures receive advance approval
A private foundation proposed an internship program connected to its scholarship program but also open to some students who did not qualify for scholarships. Internships at nonprofits, government…
Employee-relative scholarship procedures receive approval
A private foundation proposed to fund college scholarships for children and other relatives of employees through a public charity's established national scholarship program. Applicants had to…
Teacher innovation fellowship grant procedures receive approval
A private foundation proposed a competitive fellowship program for educators who developed innovative entrepreneurship and engineering teaching approaches. Recipients would be selected through…
Artist residency and grant procedures receive approval
A private foundation proposed an artist and scholar residency program plus several grant opportunities for artistic and scholarly work. Residencies would bring together participants from varied…
Emergency management fellowship procedures receive approval
A private foundation proposed a research fellowship for experienced emergency management professionals and scholars. Fellows would study disaster communication, logistics, hazard mitigation, or…
Foundation scholarship procedures qualify for advance approval
A private foundation asked the IRS to approve procedures for scholarships serving high-achieving students with limited financial means in two local areas. Applicants must meet academic and…
Travel grants for fellowship reunions receive advance approval
A private foundation proposed travel grants so current and former military fellowship recipients could attend educational and networking reunions. The school and military branch select the fellows,…
Internship and media fellowship grant procedures approved
A private foundation proposed two individual grant programs to develop recipients' professional skills. One program supports unpaid internships and classroom study at section 501(c)(3) educational…
Need-based STEM scholarship procedures approved
A private foundation proposed scholarships for college freshmen and sophomores pursuing STEM degrees. Financial need is the primary criterion, and applicants also provide references, a transcript,…
Community-focused scholarship procedures approved
A private foundation proposed scholarships for students in a specified location who attended schools it supported or demonstrated service to the local community and people in poverty. Eligible…
Four-year high school scholarship procedures approved
A private foundation proposed four-year scholarships for graduating seniors from a specified high school who enroll full time at accredited four-year institutions. Applicants must meet a minimum…
Employer-related scholarship procedures approved
A private foundation proposed scholarships for employees and children of employees connected with a large membership organization and related employers. Eligibility and selection are based on…
Educational leadership grant procedures receive advance approval
A private foundation sought advance approval for a two-phase educational grant program intended to develop future professionals and leaders in a religious community. College participants would…
Educational leadership grant procedures receive advance approval
A private foundation sought advance approval for a two-phase educational grant program intended to develop future professionals and leaders in a religious community. College participants would…
Equine scholarships and youth travel grants receive advance approval
A private foundation devoted to horsemanship and horse welfare proposed two grant programs. One would provide need-based scholarships to high school graduates pursuing degrees in equine-related…
Two local scholarship programs receive advance approval
A private foundation proposed two scholarship programs for students with ties to its local area. One program would support seniors from a specified public high school who had at least a 3.0 grade…
Educational leadership grant procedures receive advance approval
A private foundation sought advance approval for a two-phase educational grant program intended to develop future professionals and leaders in a religious community. College participants would…
Educational leadership grant procedures receive advance approval
A private foundation sought advance approval for a two-phase educational grant program intended to develop future professionals and leaders in a religious community. College participants would…
Peace and nonviolence scholarship procedures receive approval
A private foundation proposed a renewable scholarship for graduating students from a specified high school. The program would honor students who promoted peace and nonviolence or pursued…
Educational leadership grant procedures receive advance approval
A private foundation sought advance approval for a two-phase educational grant program intended to develop future professionals and leaders in a religious community. College participants would…
Educational leadership grant procedures receive advance approval
A private foundation sought advance approval for a two-phase educational grant program intended to develop future professionals and leaders in a religious community. College participants would…
Educational leadership grant procedures receive advance approval
A private foundation sought advance approval for a two-phase educational grant program intended to develop future professionals and leaders in a religious community. College participants would…
Educational leadership grant procedures receive advance approval
A private foundation sought advance approval for a two-phase educational grant program intended to develop future professionals and leaders in a religious community. College participants would…
Employer and carrier scholarship procedures receive advance approval
A private foundation asked for advance approval of an employer-related scholarship program for domestic and international company employees, employees of qualified truckload contract carriers, and…
Private foundation scholarship procedures are approved
A private foundation requested advance approval for three scholarship programs serving financially needy students at a school. A school committee considers character, academic excellence, and…
Private foundation educational grant procedures are approved
A private foundation proposed a grant program giving participants direct experience in affordable housing, historic preservation, or open-space preservation. Applicants must have at least a…
Private foundation scholarship procedures are approved
A private foundation proposed making 15 to 20 scholarships each year to encourage local high school graduates to pursue higher education. Applicants are scored on academic excellence, community…
Scholarship procedures receive approval effective from filing
A private foundation created a scholarship program for graduates of a particular school who plan to pursue college degrees. Applicants provide proof of acceptance, an essay, recommendations, and…
Conservation-scientist fellowship procedures are approved
A private foundation proposed a one-year fellowship offering intensive communication, leadership, policy, and management training to conservation scientists in specified regions. Fellows would be…
Local college scholarship procedures are approved
A private foundation proposed two years of scholarships for graduating seniors from three local public high schools who had at least a 2.5 grade-point average, qualified for free or reduced-price…
Foundation asset transfer receives broad excise-tax rulings
After a corporate reorganization, one private non-operating foundation transferred cash, stock, two assigned grant commitments, and an endowment grant to a newly created, commonly controlled private…
Related foundations may transfer assets, but not qualifying-distribution carryovers
A private foundation transferred cash, publicly traded stock, and two grant commitments to a related private foundation after their corporate sponsor reorganized. The IRS ruled that the transfer…
College scholarship procedures receive advance approval
A non-exempt charitable trust that was also a private foundation requested advance approval for a college scholarship program. Eligible students had to complete two years in specified science or…
Two community fellowship programs receive advance approval
A private foundation proposed two grant programs for individuals working on charitable, educational, professional-development, and community-improvement projects in two geographic areas. One program…
Set-aside for a second disability group home is approved
A private foundation requested approval to set aside funds for a second group home serving people with a named syndrome and other developmental disabilities. The foundation needed time to study…
Scholarship and artist-grant procedures receive advance approval
A private foundation proposed scholarships for students who lacked resources for higher education and grants for artists developing their skills and talents. Applicants had to satisfy residency and…
Veterinary scholarship procedures receive advance approval
A private foundation operated a scholarship program for graduate students from specified counties who studied animal science and veterinary medicine at a university. A faculty committee ranked…
High-school scholarship procedures receive advance approval
A private foundation proposed scholarships for graduating seniors at a specified high school who planned full-time undergraduate study. It publicized the program to all seniors and evaluated…
Law-school diversity scholarship procedures receive approval
A private foundation proposed one-time scholarships for first-year students at accredited law schools to help pay second-year educational costs. Eligible students had to contribute to the diversity…
Peace-education scholarship procedures receive approval
A private foundation proposed nonrenewable scholarships for financially needy graduate students studying peace education or conflict management. Applicants had to be recent graduates enrolled in…
Renewable community scholarship procedures receive approval
A private foundation proposed renewable scholarships for residents of a city and surrounding area attending colleges, universities, or vocational-technical schools. Candidates were nominated by…
Scholarship procedures for physically disabled students receive advance approval
A private foundation proposed scholarships for academically promising students with physical disabilities and financial need to attend private primary and secondary schools. The foundation planned…
Foundation receives five-year extensions to dispose of inherited business holdings
A private foundation acquired interests in several real-estate development businesses through a transfer from another foundation that had received them as part of an unusually large and complex…
Foundation receives five-year extensions to dispose of inherited business holdings
A private foundation acquired interests in several real-estate development businesses through a transfer from another foundation that had received them as part of an unusually large and complex…
College scholarship procedures receive advance approval
A private foundation proposed scholarships for students pursuing college, graduate, professional, trade-school, or GED-related study who showed academic ability, motivation, or financial need. The…
Artist travel-fellowship procedures receive advance approval
A private foundation proposed merit-based travel fellowships for visual artists, curators, and critical writers in a redacted city to pursue professional development outside their home area. Arts…
Urban student scholarship procedures receive advance approval
A private foundation took over a related organization's scholarship program for students from selected urban communities. The program began with students entering seventh grade, used objective…
Religious-community leadership grant procedures receive approval
A private foundation proposed joining a related foundation and its limited liability company as an additional donor to a two-phase educational grant program. The program would prepare college…
Court-ordered land auction to disqualified person avoids self-dealing
A private foundation owned a 49.9 percent interest in a partnership holding about 6,000 acres, while a substantial contributor owned 0.1 percent and the remaining interests were held by the…
Community-service scholarship procedures receive approval
A private foundation proposed one-time scholarships for ten high school juniors or seniors who combined strong academic performance with community service, volunteer work, or mentoring. Applicants…
Healthcare scholarship procedures receive advance approval
A private foundation proposed scholarships for healthcare students attending accredited domestic universities, technical colleges, or other qualifying programs. It aimed to improve healthcare in…
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.