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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Revised college scholarship procedures approved
A private foundation sought approval for revised procedures governing renewable scholarships for undergraduate students at accredited two-year and four-year schools in a specified state. Applicants…
Nonprofit leader grant procedures approved
A private foundation proposed up to 30 grants for full-time leaders of nonprofits that had recently received foundation grants. The awards would support professional development, personal and…
Economics research grant procedures approved
A private foundation proposed two educational grant programs in economics and related fields. One would give modest, short-term grants to promising students and recent graduates for scholarly…
High school graduate scholarship procedures approved
A private foundation proposed a scholarship honoring an individual's legacy for an outstanding graduate of a specified high school. A committee of school officials and foundation representatives…
Computer science scholarship procedures approved
A private foundation proposed a nationwide, one-year scholarship for a high school senior intending to study computer science and enter professional web development. Applicants needed a minimum…
Charitable trust scholarship procedures approved
A non-exempt charitable trust that was also a private foundation proposed renewable scholarships for students from two local high schools. Applicants would be evaluated for academics, financial…
Foundation's learning-exchange grant procedures receive advance approval
A private foundation proposed grants that would let selected individuals from U.S. and U.K. charities participate in international learning exchanges. The grants would cover reasonable travel,…
Scholarship procedures for firefighter and police families receive approval
A private foundation proposed up to ten annual scholarships for full-time college students whose parent or guardian is an active firefighter or police officer in the foundation's service area.…
Hospital-bond collateral is a program-related investment and qualifying distribution
A private foundation pledged marketable securities as collateral for a surety supporting the debt-service reserve on bonds used to build and equip a charitable hospital. The pledge was essential to…
Congressional-policy fellowship grant procedures receive approval
A private foundation proposed sponsoring two professionals each year as fellows working with a congressional subcommittee on major policy issues. Candidates had to demonstrate policy knowledge and…
Scholarships for students formerly in institutional care receive approval
A private foundation proposed one-time, renewable-by-reapplication scholarships for students who were or had been residents of nonprofit or institutional children's homes, lacked a nurturing home…
Private foundation gets S corporation stock and ESOP rulings
A private foundation expected to receive more than two percent of an S corporation's stock as a gift when a related revocable trust terminated. The IRS ruled that the foundation would have five…
Art foundation receives transfer and business-income rulings
A private operating foundation expected to receive more than 25 percent of another private operating foundation's assets before the transferor terminated its private foundation status. The IRS ruled…
Employer-related scholarship procedures receive advance approval
A private foundation asked the IRS to approve an employer-related scholarship program for children of employees and independent contractors connected with two businesses. An independent committee of…
Employer-related scholarship procedures approved
A private foundation proposed nonrenewable undergraduate scholarships for children and grandchildren of a corporation's active employees. An independent administrator and outside volunteer…
Renewable scholarship procedures approved
A private foundation proposed up to four scholarships each year for high school seniors, undergraduate and graduate students, with both new and renewed awards counting toward the limit. Board…
Renewable East Coast scholarship procedures approved
A private foundation proposed renewable scholarships for high school, college, and graduate students attending or planning to attend institutions in states along the East Coast. It expected about…
Community leadership grant procedures approved
A private foundation proposed a three-year educational grant program to develop community leaders working to improve outcomes for vulnerable children. Participants would build individual leadership…
Local senior scholarship procedures approved
A testamentary trust managed by a financial institution funded renewable scholarships for graduating seniors in a specified public school system. A committee of school officials and additional…
Grants to controlled operating foundation may qualify as distributions
A private nonoperating foundation proposed unrestricted start-up and continuing grants to a related private operating foundation devoted to public art and education. The organizations shared family…
Controlled operating-foundation grants may be qualifying distributions
A private nonoperating foundation proposed unrestricted start-up and continuing grants to a related private operating foundation devoted to public art and education. The grantor, the grantor's son,…
Nursing scholarship procedures receive advance approval
A private foundation proposed annual scholarships for students entering nursing or allied health sciences programs at a specified college. A four-member advisory committee would rank applicants…
Music scholarship procedures receive advance approval
A private foundation proposed renewable scholarships for music students at a specified university. Applicants would need a minimum grade point average, financial need, and evidence of character and…
Utility-assistance grants receive favorable foundation rulings
A private foundation funded a public charity's program that helped elderly, severely disabled, and income-eligible households pay emergency energy expenses. The utility and its parent were…
Rural medical scholarship procedures receive approval
A private foundation proposed annual scholarships for students in accredited medical doctor or osteopathy programs who intended to practice in rural communities. A selection committee would evaluate…
Health-care internship grant procedures receive approval
A private foundation funded paid, academic-year internships placing local university students in health-care facilities serving Spanish-speaking and other underserved communities. Applicants were…
CLAT rulings partly approve estate deduction and foundation treatment
A charitable trust expected to receive a 20-year annuity from one of three charitable lead annuity trusts funded after the deaths of two founders, with a child holding the remainder interest. The…
Family CLAT rulings produce mixed foundation treatment
One of three family private foundations expected to receive a 20-year annuity from a charitable lead annuity trust whose remainder beneficiaries were a daughter and grandchild. The IRS conditionally…
Foundation Two CLAT rulings produce mixed treatment
One of three family private foundations expected to receive a 20-year annuity from CLAT Two, whose remainder beneficiaries were a daughter and Grandchild C. The IRS conditionally approved an…
Foundation One CLAT rulings produce mixed treatment
One of three family private foundations expected to receive a 20-year annuity from CLAT One, whose remainder beneficiary was a trust for a son and Grandchild A. The IRS conditionally approved an…
Trust reformation correcting clerical error was not self-dealing
A married couple amended a trust to reduce the share passing to a private foundation and increase the share passing to family members, but a clerical error left one of three remainder clauses…
Vocational scholarship procedures received advance approval
A private foundation proposed vocational scholarships for students and graduates of specified local schools who lacked sufficient funds for further education. An independent committee would select…
Service-learning scholarship procedures received advance approval
A private foundation proposed up to two annual scholarships for full-time college students in a specified department who participated in service-learning, cooperative education, or internships. The…
IRS approves grants supporting mid-career poets
A private foundation proposed grants for mid-career American poets to develop original lectures on poetry and poetics for free public presentation. A knowledgeable selection committee would identify…
Foundation could hold passive foreign investments through wholly owned corporation
A private foundation planned to create and wholly own a foreign corporation to manage foreign investments, including distressed debt. The corporation would earn at least 95 percent of its income…
Private foundation received advance approval for scholarship procedures
A private foundation proposed scholarships for students in specified engineering, arts, and sciences programs at two colleges. Applicants would be evaluated on financial need, grades, character…
Foundation received approval for scholarships and service-oriented educational grants
A private foundation proposed grants for college students and recent graduates participating in educational programs, service projects, internships, and fellowships. Applicants had to meet academic,…
Employer-related scholarships received advance approval
A private foundation proposed one-year scholarships for children of employees in a group of related companies who were entering college, university, or vocational school. An independent committee of…
Scholarship procedures for students overcoming difficulties received approval
A private foundation proposed scholarships for students who had overcome difficulties to finish high school, needed financial help, and did not qualify for academic or athletic scholarships. Its…
High school scholarship procedures received advance approval
A private foundation proposed scholarships for graduating seniors from a specified high school who would attend accredited four-year U.S. colleges or universities. A committee consisting of the…
Scholarship procedures for high school students and adults received advance approval
A private foundation proposed scholarships for local high school graduates and adults seeking degrees, work-related classes, or trade training. High school recipients had to maintain a 3.0…
Private foundation merger and later termination avoided excise taxes
An irrevocable charitable trust proposed transferring all its assets to another private foundation controlled by the same people, merging into that foundation, and then voluntarily terminating. A…
Individual innovation-grant procedures received advance approval
A private foundation operated a grant program addressing scientific and technological barriers to high-impact global health and development solutions. It proposed expanding the program from…
Cosmetology scholarship procedures received advance approval
A private foundation operated a scholarship program for students entering or attending cosmetology or barber school. An independent committee would score applicants using essay quality, interest in…
Court reformation of charitable remainder trust avoided self-dealing
A charitable remainder trust was intended to pay a fixed percentage of its assets each year, but the drafting attorney used language that limited payments to trust income. The trustees had…
Private foundation's high school scholarship procedures were approved
A private foundation proposed a one-year scholarship program for financially needy and deserving graduates of a specified high school. Applicants had to meet a minimum grade-point average and were…
Private foundation's renewable scholarship procedures were approved
A private foundation proposed scholarships for graduates of a specified school district's high schools who attend an accredited postsecondary degree program full time. Recipients could reapply…
Apartment rent and parking avoided UBIT, but coin laundry did not
A private operating foundation planned to receive a debt-free apartment complex from its grantor and trustee. The IRS ruled that the complex was not a business enterprise subject to the excess…
Photography grant procedures received advance approval
A private foundation proposed an educational grant program focused on photography and related fields. Eligible recipients included photographers, writers, scientists, other professionals, teachers,…
Employer-related scholarship procedures receive advance approval
A private foundation proposed two employer-related scholarship programs, one for employees and one for employees' dependent children. An outside administrator would receive applications, apply…
Need-based community scholarship procedures receive approval
A private foundation proposed need-based scholarships for members of a defined community in a particular geographic region. Applicants had to attend an eligible post-secondary or vocational…
Art and media grant procedures receive advance approval
A private foundation proposed three grant programs for individuals working on community art, digital access to news and information, and experimental journalism or media tools. Applicants would be…
CLAT payments on charitable pledges avoid self-dealing
A married couple served as trustees of a private foundation and created revocable trusts that called for testamentary charitable lead annuity trusts. Separate agreements assigned charitable payments…
Testamentary CLAT payments do not create self-dealing
A married couple served as trustees of a private foundation and arranged for testamentary charitable lead annuity trusts to make payments under separate hospital and museum pledge agreements. The…
Foundation receives five more years to dispose of business stock
The IRS extended a private foundation's period for disposing of donated corporate stock by five additional years under IRC § 4943(c)(7). The foundation and other shareholders had repeatedly tried to…
Employee-family scholarship procedures receive advance approval
The IRS approved a private foundation's procedures for scholarships awarded to children and other relatives of employees through a public charity's nationwide competition. Applicants had to achieve…
Nominal hay lease excludes land from investment-return assets
A private foundation owned undeveloped real estate through a disregarded limited liability company. It leased the development site for no more than one dollar per year to a government…
Expanded student scholarship and support procedures approved
A private foundation asked for advance approval of expanded procedures for a student-support program that combined scholarships with mentoring, internships, cultural activities, counseling, medical…
Related foundations may combine assets without Chapter 42 penalties
A charitable trust treated as a private foundation proposed transferring all of its assets and liabilities to a related private foundation controlled by the same family. The IRS ruled that the…
Foundation matching gifts avoid private-foundation excise taxes
A private foundation took over most payments under the matching-gift program of its sole corporate contributor, which shared the foundation's officers and directors. The foundation limited matches…
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.