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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Educational grant procedures receive advance approval
A private foundation proposed joining an educational grant program that funded organizations employing educators nominated for their strong records and innovative ideas. Applications would be reviewed…
Needs-based scholarship procedures receive approval
A private foundation proposed scholarships for financially needy residents of a specified locality attending a named school. The school's president and dean of students would serve as the selection co…
Educational grant procedures receive advance approval
A private foundation proposed joining an educational grant program that funded organizations employing educators nominated for their strong records and innovative ideas. Applications would be reviewed…
Scientific research grant procedures receive approval
A private foundation proposed one-year and two-year grants for scientists conducting research at nonprofit academic, medical, and research institutions in several countries. The program aimed to accel…
Educational grant procedures receive advance approval
A private foundation proposed joining an educational grant program that funded organizations employing educators nominated for their strong records and innovative ideas. Applications would be reviewed…
Educational grant procedures receive advance approval
A private foundation proposed joining an educational grant program that funded organizations employing educators nominated for their strong records and innovative ideas. Applications would be reviewed…
Educational grant procedures receive advance approval
A private foundation proposed joining an educational grant program that funded organizations employing educators nominated for their strong records and innovative ideas. Applications would be reviewed…
Therapeutic-program grant procedures receive approval
A private foundation proposed grants to help families afford private therapeutic programs for children under age eighteen. Families had to show financial need, obtain acceptance from a treatment progr…
IRS revokes exemption after organization fails to provide records
The IRS revoked an organization's § 501(c)(3) exemption after it failed to respond to repeated requests for records about its activities, finances, and employment tax returns. Without that information…
IRS denies reinstatement because scholarships benefit a related business
An organization sought reinstatement of its § 501(c)(3) exemption after an earlier revocation for failing to file Form 990 for three consecutive years. It proposed scholarships for youth programs, but…
Welfare-benefit trust reversion avoids excise tax and UBIT
A § 501(c)(3) charity sponsored a tax-exempt voluntary employees' beneficiary association that provided health and death benefits. After terminating the trust and making one-time payments to beneficia…
Adviser-caused IRA distribution receives rollover deadline waiver
An IRA owner had enough non-IRA resources to make a third-party loan, but his financial adviser told him to fund the investment with an IRA distribution. The distributed funds were invested and were n…
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.