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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Leadership program grant procedures receive advance approval
A private foundation sought approval for a two-phase educational program intended to prepare college students for professional leadership roles in a religious community. The first phase included…
Leadership program grant procedures receive advance approval
A private foundation sought approval for a two-phase educational program intended to prepare college students for professional leadership roles in a religious community. The first phase included…
Leadership program grant procedures receive advance approval
A private foundation sought approval for a two-phase educational program intended to prepare college students for professional leadership roles in a religious community. The first phase included…
Leadership program grant procedures receive advance approval
A private foundation sought approval for a two-phase educational program intended to prepare college students for professional leadership roles in a religious community. The first phase included…
Leadership program grant procedures receive advance approval
A private foundation sought approval for a two-phase educational program intended to prepare college students for professional leadership roles in a religious community. The first phase included…
Leadership program grant procedures receive advance approval
A private foundation sought approval for a two-phase educational program intended to prepare college students for professional leadership roles in a religious community. The first phase included…
Leadership program grant procedures receive advance approval
A private foundation sought approval for a two-phase educational program intended to prepare college students for professional leadership roles in a religious community. The first phase included…
Leadership program grant procedures receive advance approval
A private foundation sought approval for a two-phase educational program intended to prepare college students for professional leadership roles in a religious community. The first phase included…
Public high school scholarship procedures receive approval
A private foundation sought approval for renewable scholarships benefiting graduating seniors at a public high school. The school principal would recommend students without a separate application,…
County scholarship procedures receive advance approval
A private foundation sought approval for scholarships supporting post-high-school education for students from a county high school, with possible expansion to other schools and home-schooled…
Employer-related scholarship procedures receive approval
A private foundation sought approval for scholarships serving eligible children of a company's employees and eligible full-time students who were themselves employees. Awards could support college,…
Leadership program grant procedures receive advance approval
A private foundation sought approval for a two-phase educational program intended to prepare college students for professional leadership roles in a religious community. The first phase included…
Law student scholarship procedures receive advance approval
A private foundation sought advance approval for scholarships benefiting senior law students in one state. A state agency publicized the program, ranked applicants using academic promise and…
Employer scholarship procedures receive advance approval
A private foundation sought advance approval for scholarships serving eligible dependent children of a company's employees. Applicants had to satisfy employment, household-income, and enrollment…
Local college and technical scholarships receive approval
A private foundation sought advance approval for nonrenewable scholarships for local students entering at least their second year of college or technical school. Eligibility required residence in…
Regional scholarships receive advance approval
A private foundation sought advance approval for scholarships helping graduating seniors from named counties attend college or a post-high-school trade or technical school. Applicants had to live in…
Beverage-industry family scholarships receive approval
A private foundation sought advance approval for scholarships for graduating high school students whose parent worked full time in the alcohol beverage industry. Applicants had to attend school in…
Entrepreneurship scholarships receive advance approval
A private foundation sought advance approval for scholarships for school-district seniors who showed entrepreneurial drive and planned higher education within the named state. Applicants submitted…
In-state undergraduate scholarships receive approval
A private foundation sought advance approval for need-based undergraduate scholarships for graduates of public high schools in three named cities. Recipients had to attend an accredited Protestant…
County graduate scholarships receive advance approval
A private foundation sought advance approval for scholarships based on financial need for graduates of high schools in a named county. The program considered student ability, extracurricular…
State college scholarship procedures receive approval
A private foundation sought advance approval for scholarships for high school seniors attending approved four-year colleges and universities within a named state. Eligibility covered citizens or…
Catholic school scholarships receive advance approval
A private foundation sought advance approval for scholarships covering tuition and books at Catholic primary and secondary schools in a named area. Applicants needed financial assistance and at…
County resident scholarships receive advance approval
A private foundation sought advance approval for scholarships for residents of a named county and state who selected their own college or university. The trust agreement considered character,…
Religious studies scholarship procedures receive approval
A private foundation requested advance approval for scholarships supporting students engaged in religious studies at seminaries or accredited colleges and universities. Eligible applicants included…
High school scholarship procedures receive approval
A private foundation requested advance approval for scholarships benefiting graduating seniors at a named high school who planned to attend two-year or four-year colleges or universities. Applicants…
Employee-child scholarship procedures receive approval
A private foundation sought advance approval for scholarships benefiting children of current employees with sufficient service and children of employees who died while employed. Applicants had to…
County student scholarship procedures receive approval
A private foundation requested advance approval for nonrenewable scholarships serving financially needy residents of a named county who attended specified local public colleges or universities. The…
Artist and activist fellowship procedures receive approval
A private foundation requested advance approval for fellowship and residency grants supporting contemporary artists and writers and Native American community activists. Separate programs would…
Community leadership program grant procedures receive approval
A private foundation sought advance approval for a two-phase educational program encouraging college students to pursue professional careers serving a religious community. The first phase combined…
County high school graduate scholarships receive approval
A private foundation requested advance approval for scholarships benefiting graduates of high schools in a named county whose families could not afford to support further education. Applicants had…
Need-based education grant procedures receive approval
A private foundation sought advance approval for education grants serving financially distressed single parents, veterans, and students studying mathematics or engineering. Applicants had to submit…
County resident scholarship procedures receive approval
A private foundation sought advance approval for scholarships serving residents of a named county and state, with preference for students who could not obtain equivalent government or private…
Educational grant procedures for organization-based programs approved
A private foundation proposed a grant program to deepen students' religious education through programs run by educational organizations. Consultants would nominate experienced educators, their…
Scholarship procedures for terrorism victims' family members approved
A private foundation proposed scholarships for dependent family members of people who died while working at its facilities during the September 11, 2001 terrorist attacks, as well as children of…
Agriculture scholarship procedures approved
A private foundation proposed funding scholarships administered by a public charity for students from a specified area who study agriculture or a related field. Applicants had to meet enrollment and…
Need-based scholarship procedures approved
A private foundation proposed funding scholarships administered by a public charity for students from a specified geographic area. Eligible applicants had to be citizens or legal residents,…
Scholarships for middle-ranked students approved
A private foundation operated a scholarship program for financially needy high school graduates who wanted to attend an accredited college in a specified state. Applicants generally had to rank in…
Blind merit scholarship procedures approved
A private foundation proposed awarding two annual merit scholarships to graduates of a specified school district. Each award covered one full year of tuition at a state-supported college or…
Need-based local scholarships approved
A private foundation proposed scholarships for high school seniors in a specified local school system who needed financial help to attend a college, junior college, or university. A committee…
College scholarship procedures approved
A private foundation proposed renewable scholarships for residents of a specified state who attended a particular college. A committee of college faculty members would rank applicants based on…
Gap-year educational stipends approved
A private foundation proposed stipends, educational advising, and mentoring for low-income students accepted into an existing program who wanted to complete a funded gap-year program before college.…
Employer-related scholarship procedures approved
A private foundation proposed undergraduate scholarships for children and grandchildren of full-time employees of a corporation and its subsidiaries. A separate public charity would administer the…
Low-income college scholarship procedures approved
A private foundation proposed two scholarship programs, and possible future programs using the same procedures, to help low-income students with academic promise complete bachelor's degrees.…
Scholarships for underprivileged local students approved
A private foundation proposed scholarships for underprivileged students under age 21 from a specified local area. Eligible applicants had to have attended high school in that area, enroll full time,…
Graduate loan scholarship procedures receive approval
A private foundation proposed making up to five interest-bearing educational loan scholarships each year to students pursuing graduate degrees in a foreign country. Applicants must show academic…
Social entrepreneur fellowship procedures receive approval
A private foundation proposed a two-year fellowship program for social entrepreneurs working on health, poverty, and conservation problems in areas of extreme poverty. Fellows would receive annual…
Scholarship procedures receive advance approval
A non-exempt charitable trust sought advance approval for scholarships to graduates of a specified high school who would attend agricultural colleges. Applicants would be evaluated on activities,…
Revised artistic research grant procedures receive approval
A private operating foundation sought advance approval for revisions to an artistic and cultural research grant program whose procedures the IRS had previously approved. The program would fund…
Foundation may set aside construction funds for educational facility
A private foundation requested approval to set aside funds for the initial construction phase of an educational and cultural facility. Its wholly owned disregarded entity would construct the…
Foundation may set aside funds for girls' dormitory renovation
A private foundation requested approval to set aside funds to restore and expand a dormitory complex used to shelter refugees and migrant children. The project would bring the building into…
Foundation's scholarship procedures receive advance approval
A private foundation asked the IRS to approve its procedures for a scholarship program serving students in a particular community. A committee of local public-school superintendents would rank…
Foundation's museum internship grants receive advance approval
A private operating foundation proposed an internship grant program supporting library, archival, and museum research. Interns could receive transportation reimbursements, housing allowances, or…
Foundation's music education grants receive advance approval
A private foundation expanded its music grant program to pay for private lessons, workshops, and short summer programs for talented middle and high school students with financial need. Independent…
Foundation's historical research fellowships receive approval
A private foundation proposed fellowships for scholarly research using its historical buildings and collections. Doctoral candidates, museum and academic professionals, and independent scholars…
Foundation's local student scholarships receive approval
A private foundation proposed scholarships for graduates of a specified school district who would continue their education in the named state, with preference for future teachers. District officials…
Foundation's church member scholarships receive approval
A private foundation proposed nonrenewable scholarships for qualifying church members attending divinity school, younger undergraduates, and high school seniors planning further education. Seminary…
Employer-related scholarship procedures receive approval
A private foundation proposed scholarships for children of qualifying consultants affiliated with a member company. Three retired academics independent of the foundation and company would select…
Foundation's nursing scholarships receive approval
A private foundation proposed scholarships for nursing students who graduated from schools in a specified county and attended an accredited nursing program in the same state. A three-person…
Foundation's local high school scholarships receive approval
A private foundation proposed scholarships for seniors at a specified high school who had lived in the local district for at least one school year and were accepted to college, university, or trade…
Charitable trust's local scholarships receive approval
A non-exempt charitable trust treated as a private foundation proposed nonrenewable scholarships for graduates of a specified school in a local district. Applicants needed at least a 3.0 grade point…
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.