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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PLR 1220038: IRS approves a foundation's employer-related scholarship program
The IRS approved a private foundation's amended employer-related scholarship program under IRC § 4945(g)(1). The program would offer scholarships to certain employees' family members and, if funds…
PLR 1220037: IRS grants additional periods to dispose of excess business holdings
The IRS approved a charitable supporting organization's request for additional five-year periods to dispose of excess business holdings in a closely held company. The organization had increased its…
PLR 1220036: IRS approves a foundation's educational travel grant programs
The IRS approved a private foundation's grant-making programs that fund educational travel for disadvantaged children and young adults. One program supports travel within participants' own country,…
PLR 1219034: IRS approves a private foundation's grant-making procedures
The IRS approved a private foundation's program to award grants to former fellows for projects improving civil legal services for poor, elderly, homeless, and disabled people and others deprived of…
PLR 1219033: IRS approves a private foundation scholarship program
The IRS approved a private foundation scholarship program for public high school students who have overcome significant obstacles and show exceptional promise or talent. The proposed program uses…
IRS approves a private foundation’s grant program for composers
The IRS approved a private foundation’s procedures for awarding grants to composers who create and perform new musical works. The program used an application, a selection committee, objective…
IRS approves a private foundation’s grant program for teachers
The IRS approved a private foundation’s procedures for awarding grants to licensed teachers for personally renewing and intellectually revitalizing projects. The program required applications,…
IRS approves an employer-related scholarship grant program
The IRS approved a private foundation’s employer-related scholarship program for children of an employer’s employees. An independent scholarship administrator would receive applications, select…
PLR 1216044: IRS approves a private foundation's academic research grant program
A private foundation asked the IRS to approve its procedures for awarding grants to college and university professors for academic research on financial markets, futures, and derivatives. The…
PLR 1216043: IRS approves a private foundation's scholarship procedures
A private foundation asked the IRS to approve a scholarship program for needy students enrolled in schools in a redacted country. The foundation proposed objective and nondiscriminatory selection…
PLR 1216042: IRS approves an employer-related scholarship program
A private foundation asked the IRS to approve a scholarship program for current and future employees of a redacted employer and their dependents. The program would use an independent selection…
PLR 1216041: IRS approves a fellowship and grant program for education initiatives
A private foundation asked the IRS to approve a program that would fund fellowships and grants for recent college graduates working in low-income schools and related social enterprises in a redacted…
IRS approves a private foundation's amended scholarship procedures
The IRS approved a private foundation's amended procedures for awarding scholarships to graduates of a specified school. The foundation sought to stop sending annual notices to employees of a…
IRS approves a Parkinson's disease research grant program
The IRS approved a private foundation's program to award research grants for work on the causes and cure of Parkinson's disease. The foundation will solicit nominations from qualified nonprofit…
PLR 1212023: IRS waives the 60-day rollover deadline after an adviser error
The IRS waived the 60-day deadline for a taxpayer to roll retirement-plan distributions into a rollover IRA. The taxpayer intended a direct rollover, but a financial adviser mistakenly placed the…
PLR 1212022: IRS waives the 60-day IRA rollover deadline after a custodian error
The IRS waived the 60-day deadline for an older taxpayer to roll an IRA distribution into a rollover IRA. The taxpayer instructed a financial institution to move the funds back into the IRA, but the…
PLR 1212021: IRS permits a surviving spouse to roll over an inherited IRA through an estate
The IRS ruled that a surviving spouse who was the personal representative and sole beneficiary of the deceased spouse's estate could roll the deceased spouse's IRA into an IRA in the survivor's own…
PLR 1210040: Lead-poisoning project set-aside qualifies as a distribution
The IRS approved a private foundation’s set-aside of funds for a childhood lead-poisoning project. The project would fund lead-hazard removal in roughly 57 housing units in high-risk neighborhoods,…
PLR 1210039: Private foundation's conference-grant procedures approved
The IRS approved a private foundation's procedures for grants that help individuals attend educational conferences and, in some cases, present or conduct related research. The foundation will use an…
PLR 1210038: International museum research award procedures approved
The IRS approved a private operating foundation's procedures for awards to individuals working with recognized international museums or art institutes. The awards will fund travel, meals, lodging,…
PLR 1208037: IRS approves private foundation's clinical research grant procedures
The IRS approved a private foundation's proposed program to give grants to clinicians and research scientists studying a redacted disease and building a clinical information and biosample…
PLR 1207012: IRS approves a private foundation's scholarship grant procedures
The IRS approved a private foundation's proposed scholarship grant-making program for children who demonstrate merit and financial need, including recipients outside the foundation's country. The…
PLR 1207011: IRS approves a private operating foundation's education grant procedures
The IRS approved a private operating foundation's grant program for students pursuing additional education in a specified location. The program would cover school costs and could provide a family…
PLR 1207010: IRS approves a private foundation's dialogue grant program
The IRS approved a private foundation's program to award one annual grant to an individual who wants to develop an understanding of a specified movement and lead dialogues in the community.…
PLR 1206019: Estate transaction involving a private foundation's expectancy and a promissory note
A private foundation expected to receive property from an estate, but the estate lacked enough cash and notes to satisfy the bequest. The foundation proposed that family members who were…
PLR 1205019: IRS approves a private foundation's scholarship grant program
The IRS approved a private foundation's proposed scholarship program for high school seniors attending public schools in a specified county and state. The program uses applications, references,…
PLR 1205018: IRS approves merit and need-based university scholarships
The IRS approved a private foundation's plan to provide merit-based and need-based scholarships through a university. Merit awards use academic thresholds, while need-based awards use federal…
PLR 1205017: IRS approves grants for artists and other creative professionals
The IRS approved a private foundation's grant program for artists, authors, architects, urban planners, investigative journalists, and people with similar expertise. Grants may support a specific…
PLR 1205016: IRS approves an employee-related scholarship program
The IRS approved a private foundation's plan to provide up to six scholarships each year to dependents of employees of a corporation and its subsidiaries. Awards may be used for tuition and related…
PLR 1204015: IRS approves a private foundation's scholarship program
The IRS approved a private foundation's proposed two-year scholarship program for graduating high school seniors. The program would award redacted amounts to students attending accredited…
PLR 1204014: IRS approves medical-care, research, and scholarship grant procedures
The IRS approved a private foundation's proposed grant procedures under IRC § 4945(g). One program would fund medical missions and research addressing human illness for which adequate treatment or a…
PLR 1203029: IRS approves an employer-related scholarship program
The IRS approved a private foundation's proposed scholarship program for children of employees of a related employer. The program uses an external selection committee, excludes disqualified persons…
PLR 1203028: IRS approves grants for a leadership development program
The IRS approved a private foundation's proposed grant program for executive directors and other senior leaders of organizations it funds. The grants pay for participation in a week-long residential…
PLR 1203027: IRS approves scholarships for employees' children
The IRS approved a private foundation's scholarship program for dependent children of eligible employees. An independent scholarship administrator will receive applications, select recipients,…
PLR 1203026: IRS approves rural scholarships and educator grants
The IRS approved two private foundation grant programs serving rural communities. One program provides scholarships to students attending accredited postsecondary institutions, and the other…
PLR 1202037: IRS approves a private foundation's scholarship grant procedures
The IRS approved a private foundation's procedures for funding undergraduate scholarships through a publicly supported organization. The scholarship program serves students pursuing careers in a…
PLR 1202036: IRS approves a medical scholarship grant program
The IRS approved a private foundation's procedures for awarding a scholarship to an individual pursuing a medical degree at a redacted school. The scholarship is selected through a committee using…
PLR 1202035: IRS approves an employer-related scholarship program
The IRS approved a private foundation's employer-related scholarship procedures for children and other relatives of employees of a company and its eligible subsidiaries. The program uses independent…
PLR 1202034: IRS approves an employer-related scholarship program
The IRS approved a private foundation's employer-related scholarship procedures for children and other relatives of employees of a company and its eligible subsidiaries. The program uses independent…
PLR 1202033: IRS approves a graduate scholarship program
The IRS approved a private foundation's procedures for awarding scholarships to first-year master's or doctoral students in a redacted field of study. The program limits awards by institution, uses…
PLR 1202032: IRS approves broad scholarship grant-making procedures
The IRS approved a private foundation's procedures for awarding scholarships for study at qualified educational institutions. The procedures cover several possible scholarship categories, including…
PLR 1202031: IRS approves a rural-county scholarship program
The IRS approved a private foundation's scholarship procedures for students from eligible rural counties who demonstrate financial need and meet academic and other criteria. The program can cover…
PLR 1202030: IRS approves an employer-related graduate scholarship program
The IRS approved an employer-related scholarship program for eligible children of employees of a redacted company who pursue post-graduate study. Eligibility depends on employment history,…
PLR 1152022: IRS approves a private foundation's community scholarship program
The IRS approved a private foundation's proposed scholarship program for high school seniors connected to a redacted community through a local high school or a qualifying employer. The program uses…
PLR 1152021: IRS approves debt funding for charitable set-aside expenditures
The IRS ruled that a private foundation may use loans to pay all or part of the costs of a construction project funded through previously approved IRC § 4942(g)(2) set-asides. The foundation serves…
Determination 1147037: IRS approved a research grant program for scholars
The IRS approved a private foundation's proposed grant program for doctoral candidates and post-doctoral researchers in science, engineering, technology, and related interdisciplinary fields. The…
Determination 1147036: IRS approved a scholarship program for students
The IRS approved a private foundation's scholarship program for students to attend a redacted program at a redacted location. The foundation planned to award one or two nonrenewable scholarships…
PLR 1146019: IRS approves a foundation's set-aside for a disability-services facility
The IRS approved a private foundation's proposed set-aside for an expansion project at a camp serving disabled children and adults. The set-aside would support construction of an expanded dining…
PLR 1146018: IRS approves scholarships for combat veterans pursuing graduate study
The IRS approved a private foundation's proposed scholarship program for combat veterans pursuing graduate study in statecraft or national security. The program uses military service, admission,…
PLR 1145027: IRS approves a diabetes research program-related investment
The IRS considered whether a private foundation's agreement to fund diabetes research at a hospital qualified as a program-related investment. The agreement funded research aimed at developing…
PLR 1145026: IRS approves estate sales under the self-dealing exception
An estate planned to sell limited partnership interests to the partnerships and distribute the cash proceeds to a charitable lead unitrust. The IRS considered whether the sales qualified for the…
PLR 1144036: IRS approves a foundation's procedures for research fellowships
A private operating foundation asked the IRS to approve its procedures for awarding grants to individuals who conduct research on nuclear security and other important global policy issues. The IRS…
PLR 1144035: IRS approves procedures for a two-year fellowship program
A private foundation asked the IRS to approve procedures for a new grant program supporting young people pursuing entrepreneurial activities and innovative scientific or technical ideas. The program…
PLR 1144034: IRS approves scholarship programs for students and teachers
A private foundation asked the IRS to approve two scholarship programs. One program would support students graduating from a public school district who plan to attend college, university, or…
PLR 1144033: IRS approves a scholarship for high school seniors
A private foundation asked the IRS to approve a scholarship program for deserving high school seniors at a redacted school. The program uses a published five-point rubric covering academic…
PLR 1143026: IRS approves scholarship and teacher-program grant procedures
The IRS approved a private foundation’s procedures for a high school student scholarship contest, a teacher research program, and a teacher professional-development program. The programs used stated…
PLR 1143025: IRS approves a private foundation’s college scholarship procedures
The IRS approved a private foundation’s procedures for awarding one-time college scholarships to high school seniors. Eligibility depended on enrollment and other stated criteria, and the selection…
PLR 1143024: IRS approves journalism fellowship and scholarship procedures
The IRS approved a private foundation’s procedures for fellowships to professional journalists and scholarships to journalism students. The program was intended to support articles and feature…
PLR 1143022: IRS approves a private foundation's endowment grant and related award program
The IRS ruled that a private foundation's endowment grant to another private foundation would support exempt charitable, educational, and scientific purposes and would not jeopardize the grantor's…
PLR 1140029: Foundation's set-aside qualifies as a distribution
A private operating foundation asked whether it could treat a set-aside for energy-efficient window replacement and drainage improvements as a qualifying distribution. The projects involved…
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.