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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Nonprofit insurer restructuring received tax-free reorganization rulings
A nonprofit health insurance organization completed a restructuring that placed a new nonprofit holding company above it and moved several subsidiaries and disregarded entities within the group. The…
Group trust may redeem an investor through an in-kind transfer
A collective group trust limited its investors to eligible retirement arrangements and other qualifying group trusts. It proposed satisfying a withdrawing retirement plan's interest with a pro rata…
Land rights transfer qualified for section 351 nonrecognition
An Alaska Native Regional Corporation proposed transferring specified land rights to a newly formed corporation in exchange for stock. An unrelated corporation would also contribute assets for…
Foreign holding company domestication qualified as an F reorganization
A foreign holding company domesticated under state law and became a domestic corporation. For federal tax purposes, it was treated as transferring all assets and liabilities to the domestic…
Corporation received relief for inadvertent termination of its S election
An S corporation retained accumulated earnings and profits from earlier C corporation years. For three consecutive years, more than 25 percent of its gross receipts came from passive investment…
Supplemental ruling extended the corrective filing deadline to 60 days
The IRS supplemented and modified an earlier private letter ruling dated October 18, 2024. The public supplemental letter does not restate the facts or describe the underlying relief. It extends the…
Parties received 75 days to make a late section 336(e) election
Purchasers acquired all stock of an S corporation from its shareholders, and the parties intended to treat the stock sale as an asset sale under section 336(e). They did not timely attach the…
Dance scholarship and educational grant procedures approved
A private foundation proposed a one-time award program for students who have participated in dance. Recipients may use funds for books and tuition under the scholarship rules or for dance lessons,…
Scholarship and educational grant procedures approved
A private foundation proposed two programs for United States citizens and legal residents. One program will fund undergraduate or graduate study, with payments made directly to educational…
Employer-related scholarship procedures approved
A private foundation proposed two scholarship programs for employees of a company. Each program will make one annual award to an employee who meets its academic and personal criteria, and an…
Historical research grant procedures approved
A private foundation proposed a program funding individual research projects about a city's history, culture, archaeology, architecture, and preservation. Applicants must propose defined work…
Set-aside for domestic violence housing approved
A private foundation requested approval to set aside funds for additional transitional housing for women and children affected by domestic violence. The foundation already operates a housing program…
International educational travel grants approved
A private foundation proposed an educational travel program for female students at rural high schools. The program will take a cohort outside the United States for cultural and educational…
Multiemployer plan amortization extensions approved
A multiemployer pension plan requested automatic extensions for amortizing three unfunded liability bases beginning with its 2023 plan year. The plan submitted an actuary's certification that it met…
Scholarships for students facing disabilities approved
A private foundation proposed scholarships for graduating seniors at one high school who face a health, physical, or learning disability. Applicants must plan to attend a college, vocational,…
Governmental affiliate excused from filing Form 990
A tax-exempt organization asked to be excused from filing annual Form 990 information returns. The IRS determined that the organization qualifies as a governmental unit or an affiliate of a…
Agricultural career scholarships approved
A private foundation proposed annual scholarships for graduating students from one county who have been accepted to study for careers in agriculture. Applicants must provide contact information,…
Community project grant procedures approved
A private foundation proposed grants for community projects supporting economic viability, community building, and historic preservation in a town and nearby communities. Individuals, businesses,…
Historic restoration matching-grant set-aside approved
A private foundation requested approval to set aside funds for a matching grant supporting restoration of ornamental plaster and murals at a historic property. The recipient organization must raise…
Historic residency-site restoration set-aside approved
A private foundation requested approval to set aside funds for a matching grant to restore a historic property used as a residency site. The project includes masonry and exterior restoration, work…
International dispute-resolution fellowships approved
A private foundation proposed fellowships for non-United States citizens to study dispute-resolution practices in the United States and apply them in their home countries. Applicants must be fluent…
Three need-based scholarship programs approved
A private foundation proposed three programs serving students from low-income and resource-poor communities. One provides educational services and scholarship support during high school, another…
Church auxiliary excused from filing Form 990
A section 501(c)(3) organization asked to be exempt from filing annual Form 990 information returns. The IRS determined that it qualifies as an integrated auxiliary of a church. Treasury Regulation…
Regional four-year university scholarships approved
A private foundation proposed four-year scholarships for graduating seniors from specified under-resourced areas to attend either of two partner universities. Selection considers financial need,…
One-time restructuring transfer treated as unusual grant
A publicly supported organization expected to receive most of the net assets of an affiliated section 501(c)(4) organization as part of a restructuring and merger. The transferor was not…
Need-based medical school scholarships approved
A private foundation proposed one-time scholarships for students attending accredited medical schools in the United States. Applicants must document academic readiness, activities and experience,…
Employee-children merit scholarships approved
A private foundation proposed merit scholarships for children of employees of a company and its subsidiaries. An independent nonprofit will run the academic competition, select finalists, administer…
Member benefit organization denied section 501(c)(3) status
An organization formed by employees and volunteers of a local government agency collected dues to provide benefits to members during hardships and celebratory life events. Benefits included…
Religious recovery home denied section 501(d) status
An organization planned to operate a religious residential recovery home for people recovering from substance abuse. Although its program included prayer, Bible reading, church attendance,…
Member funeral benefit organization denied section 501(c)(3) status
A membership organization collected membership and registration fees to provide cash, material, and spiritual support when a member or a member's immediate family member died. The IRS concluded that…
Pharmaceutical consulting organization denied section 501(c)(3) status
An organization proposed to provide paid consulting services to pharmaceutical companies concerning pediatric skin diseases and donate the net proceeds to exempt organizations supporting research…
Carbon-free energy business denied section 501(c)(3) status
An organization planned to design, build, own, and operate carbon-free electrical generation facilities, initially using solar panels and battery storage. It expected to earn fees for installed…
Veterans' public restaurant and bar denied section 501(c)(3) status
A veterans' organization operated a restaurant and bar open to the general public every day, with prices comparable to other restaurants. It also raised funds and provided assistance for veterans,…
Exemption revoked for inadequate records, nonresponse, and private benefit
The IRS revoked an organization's section 501(c)(3) exemption after it failed to substantiate its activities, provide complete financial records, or respond to repeated information requests. The…
Partnership granted extension to make late section 754 election
A limited liability company treated as a partnership intended to make a section 754 election but inadvertently failed to attach a valid election to its timely partnership return. The IRS found that…
Estate granted extension to elect portability of unused exclusion
An estate that represented it was not otherwise required to file Form 706 failed to file a timely return electing portability of the decedent's unused estate and gift tax exclusion to the surviving…
Extension granted for late section 336(e) election
A consolidated group's parent distributed all the stock of several target corporations and intended the qualified stock disposition to be treated as an asset sale under section 336(e), but the…
Artist and nonprofit-leader grant procedures approved
A private foundation proposed two educational grant programs. One makes grants to artists at different career stages for artistic exploration and growth. The other funds sabbaticals for leaders of…
Large construction grant recognized as an unusual grant
A publicly supported charity expected a large, unexpected cash grant from a grantor with no prior connection to the organization. The charity planned to use the installments for a playground,…
Exemption revoked for inadequate records and unsubstantiated operations
The IRS revoked an organization's section 501(c)(3) exemption because it did not prove that it operated exclusively for scientific, educational, charitable, or other exempt purposes. During the…
Estate received 120 days to make a late portability election
An estate that was not otherwise required to file Form 706 missed the deadline to elect portability of the deceased spouse's unused estate and gift tax exclusion. The estate requested regulatory…
Late taxable REIT subsidiary election treated as timely
A real estate investment trust and its wholly owned subsidiary intended the subsidiary to operate a restaurant as a taxable REIT subsidiary. An internal communication failure left the finance team…
Late S corporation elections and inadvertent termination relief granted
A corporation and its shareholders intended S corporation treatment, but the entity classification and S elections were not filed on time. The corporation also had an ineligible shareholder, which…
Partnership received 120 days to make a late section 754 election
A partnership missed the deadline to make a section 754 election after one of its partners died. The IRS found that the partnership satisfied the standards for regulatory election relief and granted…
Late qualified opportunity fund self-certification accepted
A partnership was formed to operate as a qualified opportunity fund, but its accountant did not know that Form 8996 had to be filed on time to make the required self-certification election. The…
REIT may exclude default deposit and legal-fee settlement from income tests
A real estate investment trust agreed to sell residential properties, but the buyer failed to close. After litigation and an appeal, the REIT received the buyer's earnest-money deposit as liquidated…
Private foundation scholarship procedures approved
A private foundation requested advance approval for a scholarship program serving graduating high school seniors from specified school districts. Recipients would be selected using financial need,…
Church-affiliated organization excused from filing Form 990
A section 501(c)(3) organization asked the IRS to excuse it from filing annual Form 990 information returns. Based on the submitted information, the IRS classified it as an organization affiliated…
Historic-property matching grant set-aside approved
A private foundation proposed setting aside funds for a matching grant to restore a historic property used for educational programs and public tours. The grant would cover specified construction…
Historic-facility rehabilitation set-aside approved
A private foundation proposed setting aside funds for a matching grant to rehabilitate a historic facility under preservation standards. The recipient would raise the remaining project cost from…
Employer-related scholarship procedures approved
A private foundation requested advance approval for scholarships offered to children and dependents of a company's full-time employees. Applicants would be evaluated using essays, community and…
Fraternal-beneficiary exemption denied for lack of a lodge system
A membership organization sought exemption as a fraternal beneficiary society under section 501(c)(8). Its primary activity was paying burial or repatriation costs and related death benefits for…
Hospital exemption revoked for section 501(r) failures
The IRS revoked a hospital authority's section 501(c)(3) exemption after examining its compliance with the Affordable Care Act's community-health requirements. The hospital used a shared community…
Dog-genetics organization denied exemption for private benefit
An organization sought section 501(c)(3) exemption to collect, store, and distribute frozen semen from a particular dog breed and to support related education and research. Its sole member was a…
Basketball-officials association denied section 501(c)(3) status
A membership association of basketball officials sought section 501(c)(3) exemption as an organization fostering amateur sports. Its main activity was contracting with school districts and assigning…
Member art gallery denied exemption for private benefit
An arts organization sought section 501(c)(3) exemption for public classes, exhibits, festivals, artist support, and related programming. It also operated a gift shop where member artists paid…
Late QSub election extension granted
An S corporation acquired all the stock of a subsidiary and intended to treat it as a qualified subchapter S subsidiary, but did not file Form 8869 on time. The parent and subsidiary reported all…
Estate received 120 days to make a late portability election
An estate that was not otherwise required to file Form 706 missed the deadline to elect portability of the deceased spouse's unused exclusion amount. The estate requested relief so the surviving…
Business separation qualifies as a tax-free Type D spin-off
A publicly traded foreign parent planned to separate one business from another by contributing subsidiaries, receivables, and business assets to a controlled corporation and distributing all…
Estate received 120 days to make a late portability election
An estate that was not otherwise required to file Form 706 missed the deadline to elect portability of the deceased spouse's unused exclusion amount. The estate requested regulatory relief so 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.