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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Half of a private foundation's assets may move to a related foundation
Two siblings who controlled a private foundation developed different charitable goals. The foundation proposed transferring half of its assets, for no consideration and not from current income, to…
Recipient foundation may accept half of a related foundation's assets
A private foundation controlled by one sibling proposed receiving half of another private foundation's assets after two siblings developed different charitable goals. The transfer would be for no…
Revised scholarship procedures approved
A private foundation asked the IRS to approve revised procedures for scholarships awarded to graduating high school students with financial need. The IRS approved the procedures under IRC §…
Museum expansion and leases approved under private-foundation rules
A private operating foundation that runs an art museum planned a major expansion on land leased from its founder and a founder-owned entity. The IRS ruled that specified construction, utility,…
IRS approves a private foundation's scholarship grant procedures
The IRS approved a private foundation's procedures for awarding scholarships to qualifying high school graduates. The program selects students on an objective and nondiscriminatory basis, with merit…
IRS approves a private foundation's music scholarship procedures
The IRS approved a private foundation's procedures for scholarships supporting young musicians. The program is aimed at minority students with musical proficiency, leadership potential,…
IRS approves a private foundation’s scholarship grant procedures
The IRS approved a private foundation’s procedures for awarding scholarships to students pursuing academic degrees at a university. The program uses an objective and nondiscriminatory selection…
IRS approves a private foundation's scholarship grant procedures
A private foundation asked the IRS to approve its procedures for awarding scholarships under IRC § 4945(g). The program would give two scholarships to graduating seniors from two redacted high…
IRS approves a private foundation's scholarship grant procedures
The IRS approved a private foundation's procedures for awarding scholarships to qualifying students from low-income families. The foundation proposed objective selection criteria, financial-need…
Foundation may retain nonvoting LLC units without indirect self-dealing
An individual planned to transfer a nonvoting interest in a disregarded LLC to a private foundation after the individual and spouse had died. The LLC's sole asset was a note from the individual's…
Foundation may hold passive LLC interest without self-dealing or excess business holdings
A private foundation planned to receive a nonvoting interest in an LLC after the death of the founder and the founder's wife. The LLC would hold only a note from the founder's daughter and earn…
Private foundation grant procedures receive approval
The IRS approved proposed changes to a private foundation's grant program for employees of a hospital. The changes broadened the eligible fields of study, made the selection committee independent of…
Educational grant procedures receive advance approval
The IRS approved a private foundation's procedures for awarding educational grants to individuals pursuing work in fields related to social justice. The program uses objective and nondiscriminatory…
IRS denies abatement of first-tier excise tax
The memorandum concerns grants from a private operating foundation to a related organization that was not recognized as tax-exempt under IRC § 501(c)(3). The foundation did not have the written…
PLR 1348016: IRS approves a private foundation's scholarship selection procedures
A private foundation asked the IRS to approve its procedures for awarding scholarships to students pursuing undergraduate or graduate study in the arts and sciences. The IRS approved the procedures…
PLR 1347024: IRS treated affiliate organizations and their designated representatives as members for lobbying rules
The IRS ruled that a national nonprofit's affiliated organizations, together with their paid and designated volunteer officers, board members, committee members, and staff, would be treated as bona…
PLR 1346011: IRS approves museum collection loans and related services without self-dealing excise tax
A private operating foundation that runs a museum asked whether several arrangements with disqualified persons would be self-dealing. The arrangements involved free loans of library and artifact…
PLR 1345035: IRS approves a private foundation's scholarship procedures
A private foundation asked the IRS to approve its procedures for awarding scholarships to graduating seniors at a school. The proposed scholarships could cover tuition, fees, books, supplies, and…
PLR 1345034: IRS approves an early charitable distribution from a lead annuity trust
An irrevocable charitable lead annuity trust asked whether it could end early and distribute its remaining assets to a related private foundation after determining that it would run out of funds…
PLR 1345033: IRS approves an early charitable distribution from a lead annuity trust
An irrevocable charitable lead annuity trust asked whether it could end early and distribute its remaining assets to a related private foundation after determining that it would run out of funds…
Other 1343027: IRS approves a private foundation's scholarship procedures
A private foundation asked the IRS for advance approval of a scholarship program supporting qualifying high school students who participated in a specified competition. The program awards one…
PLR 1340019: IRS approves a private foundation's Christian scholarship procedures
The IRS approved a private foundation's procedures for awarding scholarships to qualifying students. The foundation will select applicants using academic history, church relationships, work…
PLR 1340018: IRS approves an artists-and-scholars residency grant program
The IRS approved a private foundation's educational grant procedures for an artists-and-scholars residency program. Residents may receive housing, meals, studio space, art materials, travel…
PLR 1336019: Private foundation receives more time to make a qualifying-distribution election
A private foundation inadvertently failed to attach a regulatory election to its Form 990-PF that would treat certain prior excess qualifying distributions as current distributions out of corpus.…
IRS approves employer-related scholarship procedures
The IRS approved a private foundation's procedures for awarding employer-related scholarships to employees of a redacted organization and their dependents. The program uses an independent selection…
IRS approves an employer-related scholarship program
The IRS approved a private foundation's procedures for an employer-related scholarship program serving children of current full-time employees. The program uses an independent administrator and…
IRS approves a qualifying distribution for property converted to an exempt use
The IRS ruled that a private foundation's transfer of property to a related private foundation, followed by conversion of the property to an exempt use, qualified as a qualifying distribution under…
IRS approves a private foundation's transfer to a related charitable trust
The IRS approved a private foundation's proposed transfer of assets to a related private foundation organized as a charitable trust. The transfer was intended to resolve disagreements among family…
IRS grants a private foundation more time to dispose of excess business holdings
The IRS granted a private foundation a five-year extension to dispose of stock that represented excess business holdings under IRC § 4943. The foundation received stock in eleven health care and…
IRS approves a private foundation's hedge fund interests under UBTI, excess holdings, and jeopardizing investment rules
The IRS ruled on a private foundation's proposed ownership of interests in an investment hedge fund organized as an LLC. The Service concluded that income from the LLC's passive investment…
PLR 1332012: IRS approves reformation of a charitable remainder unitrust
The IRS approved court-ordered changes to a net income makeup charitable remainder unitrust. The changes removed a makeup-liability provision and revised how proceeds from contributed property would…
PLR 1332011: IRS approves reformation of a charitable remainder unitrust
The IRS approved court-ordered changes to a net income makeup charitable remainder unitrust. The changes removed a makeup-liability provision and revised how proceeds from contributed property would…
IRS approves private foundation scholarship procedures
The IRS approved a private foundation's procedures for awarding scholarships and fellowships to graduate students conducting research or study through an international exchange program. The…
IRS approves scholarship procedures for employees and retirement-community families
The IRS approved a private foundation's scholarship procedures for employees of a management-services company, their dependents, and children or grandchildren of residents of a retirement community.…
PLR 1329028 approves a private foundation's receipt of hedge-fund interests
The IRS rules that a private foundation's investment income from specified interests in a hedge-fund LLC will not be unrelated business taxable income under the stated facts. The IRS also concludes…
PLR 1329027 grants a five-year extension to dispose of excess business holdings
The IRS grants a private foundation an additional five years to dispose of excess business holdings received by bequest. The foundation showed that it had made diligent efforts to sell the holdings…
Determination 1329026 revokes an organization's section 501(c)(3) exemption
The IRS issued a final adverse determination that an organization did not qualify for exemption under IRC § 501(c)(3). The organization bought television listing data and provided access to members…
PLR 1328034: IRS grants a five-year extension to dispose of excess business holdings
The IRS granted a private foundation an additional five years to dispose of excess business holdings received as a donation. The foundation represented that it had made diligent efforts to sell the…
PLR 1325021: Early termination of a charitable remainder unitrust is approved
The IRS approved the early termination of a charitable remainder unitrust and the distribution of its assets. The income beneficiaries could receive the actuarial value of their interests, while the…
PLR 1325020: Early termination of a charitable remainder unitrust is approved
The IRS approved the early termination of a charitable remainder unitrust and the distribution of its assets. The income beneficiaries could receive the actuarial value of their interests, while the…
PLR 1325019: Early termination of a charitable remainder unitrust is approved
The IRS approved the early termination of a charitable remainder unitrust and the distribution of its assets. The income beneficiaries could receive the actuarial value of their interests, while the…
PLR 1325018: Early termination of a charitable remainder unitrust is approved
The IRS approved the early termination of a charitable remainder unitrust and the distribution of its assets. The income beneficiaries could receive the actuarial value of their interests, while the…
PLR 1324019: IRS approves a private foundation's scholarship procedures
A private foundation asked the IRS to approve its procedures for awarding scholarships to qualifying college students. The proposed program uses financial need, academic performance, aptitude,…
PLR 1323029: Foundation's art subsidiary is functionally related and its management fees are not UBTI
The IRS considered a private foundation's plan to receive all stock of a corporation holding an artist's collection and copyrights. The foundation planned to use those assets for exhibitions,…
PLR 1322048: IRS approves an employer-related scholarship program
The IRS approved a private foundation's procedures for awarding scholarships to qualifying dependent children of employees and related employees. The program uses an independent selection committee…
PLR 1322047: IRS approves a need-based scholarship program for local students
The IRS approved a private foundation's procedures for scholarships to graduating high school seniors who meet academic, financial-need, residency, and enrollment criteria. The program may award up…
PLR 1321034: Estate settlement does not create self-dealing excise tax
A private foundation was named to receive partnership interests and other assets under a decedent's will. The decedent's children, the estate's executors, and the foundation's trustees became…
PLR 1321031: IRS approves employer-related scholarship grant procedures
The IRS approved a private foundation's procedures for awarding scholarships to children of an employer's full-time employees. The program considers financial need, academic merit, and educational…
PLR 1321030: IRS approves a private foundation's scholarship grant procedures
The IRS approved a private foundation's procedures for awarding a scholarship to a qualifying high school senior pursuing post-secondary education. The program is needs-based, open to the senior…
PLR 1321029: IRS approves a global employee-family scholarship program
The IRS approved a private foundation's procedures for scholarships to dependent children of eligible full-time employees and their subsidiaries. The program uses an independent third party to…
PLR 1321028: IRS approves a foundation's historic-property restoration set-aside
The IRS approved a private operating foundation's request to set aside funds for the restoration of a historic property. After restoration, the property would be used for exempt activities,…
PLR 1321027: IRS rules that a court-approved estate settlement is not self-dealing
The IRS considered a settlement involving partnership interests that a decedent's will had directed to a private foundation. The decedent's children, the estate's executors, and the foundation's…
PLR 1321025: IRS approves a private foundation's asset transfer, termination plan, and related tax treatment
A private non-operating foundation planned to transfer substantially all of its remaining assets to a related private operating foundation controlled by the same people. The IRS ruled that the…
PLR 1321024: IRS approves a private foundation's asset transfer, termination plan, and related tax treatment
A private non-operating foundation planned to transfer substantially all of its remaining assets to a related private operating foundation controlled by the same people. The IRS ruled that the…
PLR 1319033: IRS approves educational grants for fine artists
The IRS approved a private foundation's procedures for awarding one-time educational grants to fine artists. Eligible applicants are U.S. citizens who are no longer students, and recipients are…
PLR 1319032: IRS approves a scholarship program for students affected by a medical condition
The IRS approved a private foundation's procedures for awarding scholarships to qualifying college students whose lives have been affected by a redacted medical condition. Applicants must meet the…
PLR 1318008: IRS approves educational grants supporting international scholarship on American art
The IRS approved a private foundation’s procedures for awarding educational grants under section 4945(g)(3). The program will support scholarly publications about American art, including…
PLR 1317019: IRS approves mentorship grants for disadvantaged young adults
The IRS approved a private foundation's procedures for awarding educational grants under IRC section 4945(g)(3). The program will support young adults ages 18 to 30 who have faced significant…
PLR 1317018: IRS rules that an estate settlement does not create self-dealing
The IRS ruled that an estate settlement involving a private foundation would not create direct or indirect self-dealing under IRC section 4941. The estate's surviving children agreed to purchase…
IRS approves private foundation’s K-12 arts grant procedures
The IRS approved a private foundation’s procedures for educational grants to students in kindergarten through grade twelve. The program will pay up to half of qualifying tuition, training, or lesson…
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.