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 may set aside funds for animal welfare facility
A private foundation planned to renovate a donated commercial building into an animal shelter, research and training facility, and home for its grantmaking and public education programs. Design and…
Foundation may set aside funds for science fellowships
A private foundation planned a postdoctoral fellowship program supporting research in chemistry, biochemistry, and medicine. The program required time to publicize the opportunity, select fellows,…
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…
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…
Undergraduate scholarship procedures receive advance approval
A private foundation proposed scholarships for undergraduates at a specified school. Awards would be based on scholastic achievement, academic excellence, and good moral character rather than…
Needs-based college scholarship procedures receive approval
A private foundation proposed scholarships for financially needy residents of a specified locality attending a named college. The college president and dean would serve as the selection committee,…
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…
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…
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…
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…
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…
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…
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…
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…
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…
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…
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…
IRS approves educational grant procedures for private foundation program
An entity affiliated with a private foundation sought advance approval for procedures used to fund educational programs at organizations employing nominated educators. Experienced nominators would…
IRS approves educational grant procedures for private foundation program
An entity affiliated with a private foundation sought advance approval for procedures used to fund educational programs at organizations employing nominated educators. Experienced nominators would…
IRS approves postdoctoral fellowship grant procedures
A private foundation proposed a two-year postdoctoral fellowship supporting research in plant pathology or sustainable agriculture. The opportunity would be publicized through scientific journals,…
IRS approves educational grant procedures for private foundation program
An entity affiliated with a private foundation sought advance approval for procedures used to fund educational programs at organizations employing nominated educators. Experienced nominators would…
IRS approves educational grant procedures for private foundation program
An entity affiliated with a private foundation sought advance approval for procedures used to fund educational programs at organizations employing nominated educators. Experienced nominators would…
IRS approves educational grant procedures for private foundation program
An entity affiliated with a private foundation sought advance approval for procedures used to fund educational programs at organizations employing nominated educators. Experienced nominators would…
IRS approves need-based scholarship procedures
A private foundation proposed scholarships for financially needy high school graduates from a redacted local area who were enrolled in or accepted by accredited colleges and universities. Applicants…
IRS approves educational grant procedures for private foundation program
An entity affiliated with a private foundation sought advance approval for procedures used to fund educational programs at organizations employing nominated educators. Experienced nominators would…
IRS approves educational grant procedures for private foundation program
An entity affiliated with a private foundation sought advance approval for procedures used to fund educational programs at organizations employing nominated educators. Experienced nominators would…
IRS recognizes public charity as a section 4945(f) organization
A tax-exempt public charity asked the IRS to recognize it as an organization described in § 4945(f). The organization was already exempt under § 501(c)(3) and classified as a public charity under §§…
IRS approves need-based college scholarship procedures
A private foundation sought advance approval for scholarships benefiting graduates of public high schools in a specified city who would attend a designated university or its successor. A committee…
IRS approves need-based scholarships at five colleges
A private foundation sought advance approval for scholarships to financially needy students attending five named colleges and universities in one state. The schools would publicize the program, and…
IRS approves matching-grant set-aside for historic restoration
A private foundation asked to set aside funds for a matching grant to a public charity restoring a historically and culturally significant structure. The grant would cover about one-third of the…
Estate transactions avoid private-foundation self-dealing
A private foundation and related family members sought rulings on estate-plan transactions involving family companies, investment partnerships, options, redemptions, and installment notes. The IRS…
IRS approves two county college scholarship programs
A private foundation sought approval for two scholarship programs administered with another foundation for residents of a specified county. One program served graduating high school seniors…
IRS approves international elite-school scholarship program
A private foundation proposed scholarships for financially needy students from the United States and another country who would attend accredited elite schools in the United States. Applicants had to…
Estate transactions avoid private-foundation self-dealing
A private foundation and related family members sought rulings on estate-plan transactions involving family companies, investment partnerships, options, redemptions, and installment notes. The IRS…
Estate transactions avoid private-foundation self-dealing
A private foundation and related family members sought rulings on estate-plan transactions involving family companies, investment partnerships, options, redemptions, and installment notes. The IRS…
Private foundation may transfer all assets and later terminate
A trust classified as a private foundation planned to transfer all of its assets to a new private foundation controlled by the same people. It would remain as a dormant shell until receiving more…
Estate transactions avoid private-foundation self-dealing
A private foundation and related family members sought rulings on estate-plan transactions involving family companies, investment partnerships, options, redemptions, and installment notes. The IRS…
Estate transactions avoid private-foundation self-dealing
A private foundation and related family members sought rulings on estate-plan transactions involving family companies, investment partnerships, options, redemptions, and installment notes. The IRS…
Estate transactions avoid private-foundation self-dealing
A private foundation and related family members sought rulings on estate-plan transactions involving family companies, investment partnerships, options, redemptions, and installment notes. The IRS…
High school graduate scholarship procedures receive approval
A private foundation proposed one-time scholarships for graduates of a specified high school who demonstrate financial need and plan to attend college or university. A committee associated with the…
Job training and college scholarship procedures receive approval
A private foundation proposed two programs for low-income residents of a specified metropolitan area. One would pay the full cost of approved job-training programs, with selection based on factors…
Science, engineering, and teaching scholarships receive approval
A private foundation proposed scholarships for graduates of a specified school who planned to major in science, engineering, or teaching. Candidates would be ranked using academic information…
County student scholarship procedures receive approval
A private foundation proposed scholarships for financially needy residents of a specified county, with preference for students of high school, college, or professional school age. A vendor would…
Vocational and college scholarship procedures receive approval
A private foundation proposed scholarships for graduates of a specified school attending vocational or technical programs or pursuing four-year degrees. Applicants needed at least a 2.0 grade point…
Foundation's feeder-fund investment avoids private-foundation excise taxes
A private foundation awaiting reinstatement proposed investing all of its donated assets in a foreign feeder corporation that invested through a partnership in diversified fixed securities. One…
Employer-related scholarship procedures receive advance approval
A private foundation asked the IRS to approve procedures for scholarships benefiting children of employees of affiliated companies. An independent administrator and selection committee would choose…
Estate note restructuring avoids foundation self-dealing
A private foundation was due to inherit a note owed by an irrevocable trust whose beneficiaries were the decedent’s family members. Directly holding the note would create self-dealing because the…
Local college scholarship procedures receive advance approval
A private foundation asked the IRS to approve a scholarship program for long-time residents of a city and nearby communities attending one of 20 local undergraduate institutions. An independent…
Foundation educational loan procedures receive advance approval
A private foundation proposed educational loans for financially needy adults attending qualifying public colleges or universities at least half-time. Eligible students would pursue bachelor's…
IRS approves need-based scholarship procedures
A private foundation asked the IRS to approve a scholarship program for students at a particular school who require financial aid. The school selects recipients based on financial need, a minimum…
IRS approves local scholarship procedures
A private foundation asked the IRS to approve a scholarship program for students from a particular city and students attending a designated school system. A scholarship committee ranks applicants…
IRS approves college scholarship procedures
A private foundation asked the IRS to approve scholarships for students enrolled or planning to enroll at a designated college. Applicants must demonstrate financial need, above-average scholarship,…
IRS approves interest-free medical education loans
A private foundation asked the IRS to approve an interest-free educational loan program for medical students at a designated school. Applicants must show that financial assistance is necessary to…
IRS approves dance training grants
A private operating foundation asked the IRS to approve grants that help performance artists attend skills-enhancing dance programs. A selection committee evaluates applicants based on factors…
IRS approves renewable high school scholarships
A private foundation asked the IRS to approve scholarships for graduating seniors from public high schools in a designated area. Applicants must rank in the top quarter of their class, be U.S.…
IRS approves two statewide scholarship programs
A private foundation asked the IRS to approve a scholarship program with two parts for residents of a designated state. The first part gives one-time awards to high school seniors from each county…
Estate transactions and notes avoid self-dealing under safeguards
A private foundation expected to receive property through the estates and trusts of members of its founding family, all of whom were disqualified persons. The family proposed redemptions and option…
IRS approves scholarship and educational grant procedures
A private foundation asked the IRS to approve procedures for scholarships under IRC § 4945(g)(1) and educational grants under § 4945(g)(3). Its programs support advanced study, medical training, and…
IRS approves scholarships for graduating seniors
A bank-administered private foundation trust asked the IRS to approve scholarships for graduating seniors at a designated school. A three-person committee selects recipients based on academic…
Private foundation scholarship procedures approved
A private foundation proposed scholarships for graduating seniors from a specified high school, with awards paid directly to colleges or universities. A committee of local school officials would…
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.