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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IRS approves private foundation scholarship procedures
The IRS approved a private foundation’s procedures for scholarships supporting youth and young adults in undergraduate or graduate education. The program is intended for applicants who demonstrate…
PLR 1316021: IRS approves estate settlement involving a private foundation
A private foundation was named to receive partnership interests and the residue of an estate, but the bequests and related purchase options became the subject of lengthy litigation and arbitration.…
Determination 1315033 approves a private foundation scholarship procedure
The IRS approved a private foundation's procedures for awarding scholarships to qualifying students. The proposed program would provide educational grants to indigent individuals, with selection…
Determination 1315032 approves an employer-related scholarship procedure
The IRS approved an employer-related scholarship program operated by a private foundation. The program was designed to support qualifying dependents of associates and employees connected with the…
PLR 1315031: Ranch property is used directly for exempt purposes
The IRS ruled that a private foundation's ranch was used and held for use directly in carrying out charitable, educational, and scientific purposes. The ranch supported a religious retreat and a…
PLR 1311035: IRS rules donated nonvoting stock is permitted business holding
The IRS ruled that a supporting organization’s nonvoting stock in a corporation would be permitted holdings under IRC § 4943 after a related foundation received a specified portion of the…
PLR 1311034: IRS rules that two foundation grants are not self-dealing
A private foundation asked whether two grants would be treated as self-dealing under IRC § 4941. One proposed grant would fund a healthcare research center built on a university campus. The other…
IRS written determination 1310044: IRS approves scholarship grant procedures
The IRS approved a private foundation's proposed procedures for awarding one annual scholarship to a qualifying graduating science student. The approval was based on objective and nondiscriminatory…
PLR 1310042: IRS approves employer-related scholarship procedures
The IRS approved a private foundation's procedures for scholarships for children of employees of related businesses. The foundation proposed objective selection standards, an independent selection…
PLR 1308031: IRS approved changes to an employer-related scholarship program
The IRS considered changes to a private foundation’s scholarship program for children of employees of a company and its controlled group. The changes expanded the applicant pool, altered eligibility…
IRS recognizes an organization as eligible under section 4945(f)
The IRS recognized an organization as described in section 4945(f) of the Internal Revenue Code. The letter states that the organization is already exempt under section 501(c)(3) and is not a…
IRS approves a private foundation's set-aside for a museum and archaeological project
The IRS approved a private foundation's request to treat a set-aside as a qualifying distribution under section 4942(g)(2). The funds were intended to support an addition to a museum and related…
IRS approves a private foundation's set-aside for facility expansion and renovation
The IRS approved a private foundation's request to treat a set-aside as a qualifying distribution under section 4942(g)(2). The funds would help pay for an expansion and renovations at facilities on…
IRS approves a private foundation's set-aside for a hospital matching grant
The IRS approved a private foundation's request to treat a set-aside as a qualifying distribution under section 4942(g)(2). The set-aside would fund a matching grant to a public charity for…
Determination 1306025: IRS approves employer-related scholarship grant procedures
The IRS approved a private foundation’s procedures for awarding employer-related scholarships. The program will provide grants to eligible children of employees of a company and its affiliate…
Determination 1306024: IRS approves employer-related scholarship grant procedures
The IRS approved a private foundation’s procedures for awarding employer-related scholarships. The program will provide grants to eligible children of employees of a company and its affiliate…
PLR 1306023: IRS approves sale of long-held land interests without unrelated business income
The IRS considered a private operating foundation that owned land under condominium units and leased that land to unit owners. The foundation planned to sell its leased-fee interests gradually to…
IRS recognizes an organization under IRC § 4945(f)
The IRS recognized an organization as exempt from federal income tax under IRC § 501(a) because it qualifies under § 501(c)(3). The IRS also determined that the organization is not a private…
PLR 1304010: IRS approves three competitive grant programs for students
A private foundation asked the IRS for advance approval of three international grant programs for students. One program supports research projects, another provides nonrenewable graduate…
IRS approves a private foundation's scholarship grant procedures
The IRS approved a private foundation's procedures for awarding scholarships to qualifying students. The foundation proposed to award grants objectively and without discrimination, pay tuition…
PLR 1303021: Private foundation's nonvoting stock and trust holdings approved
A private foundation asked whether it could hold nonvoting stock in a corporation without incurring the excise tax on excess business holdings. It also asked whether four family and charitable…
IRS approves a private foundation's set-aside for a senior center
A private operating foundation that provides programs for seniors asked the IRS to approve a set-aside for renovating and expanding a senior center. The IRS found that the project served an exempt…
IRS approves a foundation's scholarship grant-making program
A private foundation asked the IRS to approve its process for awarding scholarships to students who would be the first in their families to attend college. The foundation proposed using…
PLR 1301015: IRS approves two fair-market-value parking arrangements
A private foundation asked whether two parking arrangements involving a related limited liability company would be self-dealing. In the first arrangement, tenants of a building on the foundation's…
IRS approves a modified scholarship grant program
The IRS approved a private foundation’s modified scholarship grant-making program under section 4945(g)(1). The changes added extracurricular-activity achievement grants to existing leadership,…
PLR 1251020: IRS approved performing-arts grant procedures for a private foundation
The IRS approved a private foundation's procedures for two performing-arts grant programs. One program would support established artists, and the other would support nominated artists with the…
PLR 1250026: IRS approved a private foundation's scholarship grant procedures
The IRS approved a private foundation's proposed scholarship program for graduating high school students who plan to attend an accredited four-year college or university in the United States or…
PLR 1251021: IRS approved a private foundation's scholarship grant procedures
The IRS approved a private foundation's proposed scholarship program for graduating high school students and current college or graduate students. The scholarships could cover tuition, books,…
Determination 1249017: IRS approves a private foundation scholarship program
The IRS approved a private foundation's procedures for awarding scholarships to students at qualifying educational institutions. The foundation planned to select recipients through an objective…
PLR 1245028: IRS approves an employer-related scholarship program
The IRS approved a private foundation's employer-related scholarship program under section 4945(g)(1). The program awards one scholarship each year to qualifying graduating high school students who…
PLR 1243015: IRS approves a private foundation's transfer of property to a related foundation
A private foundation planned to transfer real and personal property worth more than 25 percent of its assets to a related organization, Project, which was expected to qualify as a private operating…
PLR 1242013: IRS approves a foundation’s cancer research grants to individual researchers
The IRS approved a private foundation's proposed grants to individual doctors and scientists conducting research on cancer treatments, with an emphasis on pediatric and anal cancers. The foundation…
IRS approves a private foundation's employer-related scholarship program
The IRS approved a private foundation's program to award scholarships to eligible children of an employer's employees. An independent scholarship management company would administer applications,…
IRS approves a foundation’s scientific research grant procedures under section 4945(g)(3)
The IRS approved a private foundation’s procedures for awarding grants under IRC section 4945(g)(3). The proposed grants would support scientific research and development by qualified individuals,…
PLR 1239014: IRS approves a private foundation's research grant procedures
A private foundation sought advance approval for a program providing research grants to students, scholars, and historians studying the career and contributions of a redacted former senator. The IRS…
IRS determination 1237023: Private foundation set-aside approved for hospice-house construction
The IRS approved a private foundation's request to set aside funds for construction of a freestanding hospice house. The project was expected to require several years of planning, fundraising,…
PLR 1236032: Private foundation receives five more years to dispose of excess business holdings
The IRS granted a private foundation an additional five years to dispose of excess business holdings received through a QTIP trust. The foundation had sold most of the holdings but still owned a…
IRS approves a private foundation's four scholarship programs
The IRS approved a private foundation's procedures for four scholarship programs. The programs serve students seeking degrees or diploma programs, including single parents, non-traditional adult…
PLR 1235025: IRS approves an employer-related scholarship grant program
The IRS approved a private foundation's program to award scholarships to dependent children of employees of related companies. The program uses an independent selection committee, academic…
IRS approves a private foundation's scholarship and grant program
The IRS approved a private foundation's proposed scholarship and project-grant procedures under IRC § 4945(g)(1) and (3). The foundation planned to award scholarships for academic, artistic,…
IRS approves a private foundation's five-year research set-aside
The IRS approved a private foundation's request to set aside funds for a multi-year biomedical research project to develop a cure for a redacted disease. The foundation planned to fund a national,…
PLR 1232038: IRS grants a private foundation five more years to dispose of excess business holdings
A private foundation received an interest in a limited liability company as a gift and treated the interest as excess business holdings. It asked the IRS for more time to dispose of that interest…
PLR 1232037: IRS approves an employer-related scholarship program
A private foundation requested advance approval for a scholarship program for children of an employer's employees. The program would provide grants for college costs, use an independent awards…
PLR 1231016: IRS grants more time for a private foundation election
The IRS granted a private foundation an extension of time to elect to treat prior-year excess qualifying distributions as current-year distributions out of corpus. The foundation had not made the…
PLR 1231015: Proposed division of a charitable lead trust will not trigger termination tax or excise taxes
A charitable lead unitrust asked whether it could divide its assets between two successor trusts with related charitable foundations as beneficiaries. The IRS ruled that the transfers would be…
PLR 1231014: Proposed division of a charitable lead trust will not trigger termination tax or excise taxes
A charitable lead unitrust asked whether it could divide its assets between two successor trusts while preserving the charitable and remainder interests described in its trust instrument. The IRS…
PLR 1230026: IRS approves transfers of a private foundation's assets to two related foundations
A newly formed private foundation planned to transfer all of its assets to two other private foundations controlled by the same people, after receiving assets from a marital trust and charitable…
PLR 1229011: IRS extends the period to dispose of donor-advised fund excess holdings
The IRS granted a donor-advised fund an additional five-year period to dispose of excess business holdings received as a bequest. The fund held a minority interest in a closely held family company,…
IRS grants a private foundation five more years to dispose of excess business holdings
The IRS granted a private foundation an additional five-year period to dispose of shares that constituted excess business holdings. The foundation had received a minority interest in a closely held…
IRS approves a scholarship competition and grant program for students
The IRS approved a private foundation’s proposed scholarship and grant-making program under IRC § 4945(g)(1). The program would select high-school students from several schools to give short…
PLR 1227005: IRS approves a private foundation's scholarship grant procedures
The IRS approved a private foundation's proposed scholarship grant-making procedures under § 4945(g)(1). The foundation planned to award scholarships for elementary, secondary, undergraduate, and…
PLR 1226033: IRS approves a private foundation's high-school scholarship procedures
The IRS approved a private foundation's proposed scholarship grant-making program under § 4945(g)(1). The foundation planned to award a four-year scholarship to one student at each participating…
PLR 1226032: IRS approves a private foundation's high-school scholarship procedures
The IRS approved a private foundation's proposed scholarship grant-making program for high school students under § 4945(g)(1). The program would award $x per year for up to four years to one student…
PLR 1226031: IRS approves changes to an employer-related scholarship program
The IRS approved changes to a private foundation's previously approved employer-related scholarship program for children of employees of a redacted business and its subsidiaries. The program awards…
PLR 1226030: IRS approves a teacher family-engagement fellowship program
The IRS approved a private foundation's fellowship program for teachers in redacted-state public and charter schools. The program would award stipends and possible additional amounts for speaking…
PLR 1224039: IRS approves a private foundation's scientific research grant program
The IRS approved a private foundation's proposed grants to individuals conducting scientific research into consciousness and related subjects. The foundation planned to select researchers based on…
PLR 1224038: IRS approves a private foundation's scholarship grant procedures
The IRS approved a private foundation's proposed scholarship program for people employed in the produce industry and their immediate relatives. The foundation planned to select students based on…
IRS approves a private foundation's grant-making program
The IRS approved a private foundation's procedures for a grant-making program intended to develop leadership and community-development skills. The program uses an open nomination process, objective…
PLR 1222005: IRS approves a pooled fund's building reacquisition and related tax treatment
The IRS ruled on a tax-exempt organization’s plan to reacquire certain building interests from a pooled income fund in partial satisfaction of the fund’s debt. The IRS concluded that the…
PLR 1221031: IRS approves foundation payments for investment, accounting, and tax services
The IRS ruled that a private non-operating foundation may pay a related management company for investment, accounting, and tax services without those payments being acts of self-dealing under IRC §…
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.