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 1140027: IRS approves revised private-foundation scholarship procedures
The IRS approved a private foundation’s revised procedures for awarding scholarships to eligible high school, undergraduate, and graduate students. The foundation added a merit-based guideline for…
PLR 1140026: IRS approves a monitored scholarship program for a private foundation
The IRS approved a private foundation’s advance request to operate a scholarship program called Y. The program would cover tuition for undergraduate, graduate, or advanced study in the United States…
PLR 1139010: IRS approves an educational competition foundation's grant procedures
The IRS approved a private foundation's procedures for grants connected to an international student competition that develops critical thinking, teamwork, communication, and technology skills. The…
PLR 1138049: IRS approved a private foundation's need-based scholarship procedures
The IRS approved a private foundation's scholarship program for students pursuing a bachelor's degree or higher who cannot afford the cost of school. The program uses published eligibility rules,…
IRS approves a nonpartisan voter-registration program under section 4945(f)
The IRS determined that an exempt organization could qualify under section 4945(f) for an exception concerning grants supporting nonpartisan voter-registration activities. The organization planned…
PLR 1136028: IRS approves a private foundation scholarship program
The IRS approved a private foundation's proposed scholarship program for graduates of designated high schools who live in specified locations and attend or plan to attend qualifying colleges or…
PLR 1136026: IRS approves a private foundation scholarship program
The IRS approved a private foundation’s scholarship procedures for students who attend or want to attend a specified university and demonstrate financial need. The scholarship program uses a…
PLR 1135033: IRS approves a private foundation's medical scholarship program
A private foundation asked the IRS to approve procedures for scholarships to students pursuing medicine at an accredited college of medicine. The program uses stated eligibility criteria, a…
IRS written determination 1134024: contingent set-aside approved during foundation litigation
A private nonoperating foundation asked to approve a contingent set-aside for amounts it could not distribute while a court decided which hospital would succeed to a beneficiary's interest under its…
IRS written determination 1134023: school property approved for charitable foundation purposes
A private foundation planned to use a wholly owned disregarded entity to acquire land, build a school, and lease the property to an unrelated public charity for a nominal rent. The foundation asked…
PLR 1133013: IRS addresses a charity's conversion to private foundation status
A supporting organization sought to convert from public charity status to private foundation status while making a series of grants to the charity it supported. The IRS ruled that the conversion…
PLR 1133004: Trust reformation approved for charitable remainder unitrust
The IRS approved a court-ordered reformation of a trust from a net income with makeup charitable remainder unitrust to a standard charitable remainder unitrust. The ruling states that the trust was…
PLR 1132026: IRS approved a foundation's scholarship grant-making procedures
The IRS approved a private foundation's procedures for awarding scholarships to African American high school students who live in the redacted state and demonstrate financial need, academic ability,…
PLR 1132025: IRS approved a fellowship grant-making program for rural community leadership
The IRS approved a private foundation's fellowship grant-making procedures under section 4945(g)(3). The fellowship is intended to strengthen community-building skills and rural community vitality…
PLR 1132024: IRS approved expanded scholarship grant-making procedures
The IRS approved a private foundation's expansion of an existing scholarship program under section 4945(g)(1). The expanded program will support single mothers pursuing higher education, financially…
Determination 1131033: Foundation set-aside approved for a matching restoration grant
The IRS approved a private foundation's set-aside for a matching grant to restore a historically significant property in a public park. The foundation planned to fund one third of the project cost,…
PLR 1131032: Foundation set-aside approved for matching restoration grant
The IRS approved a private foundation's set-aside for a matching grant to restore a historically and architecturally significant property in a public park. The foundation planned to fund one third…
PLR 1130008: IRS finds a planned property exchange was not self-dealing after trustees resigned
A private foundation planned to exchange a residential property it owned for another house owned by a former trustee. The former trustee and her spouse had resigned from the foundation’s board…
PLR 1130007: IRS approves a foundation’s set-aside for a group home project
The IRS approved a private operating foundation’s set-aside for the purchase and modification of a residential facility for people with a specified medical condition. The foundation planned to use…
PLR 1130006: IRS approves a private foundation’s transfer of assets to another foundation
A private foundation planned to transfer about half of its assets, consisting of cash and securities, to another private foundation established to pursue separate charitable objectives. The IRS…
PLR 1129049: IRS approves a private foundation's receipt of promissory notes from estate transactions
The IRS ruled that a private foundation could receive and hold promissory notes arising from the purchase of non-voting corporate shares held by two estates. The estates were expected to transfer…
IRS approves a private foundation's healthcare set-aside
The IRS approved a private foundation's plan to treat amounts set aside over five tax years as qualifying distributions for a healthcare clinic relocation and expansion project. The foundation also…
PLR 1128026: IRS approves a private foundation's scholarship grant procedure
The IRS approved a private foundation's proposed procedure for awarding need-based scholarships to students attending post-secondary school. The foundation planned to publicize the program through…
PLR 1127012: IRS approves an employer-related scholarship program
A private foundation asked for advance approval of a scholarship program for children of employees of three related companies. The IRS approved the program under IRC § 4945(g)(1), based on objective…
PLR 1127011: IRS approves continued ownership of a wholly owned company with passive income
A private foundation asked whether its continued ownership of all the stock of a related company would create excess business holdings under IRC § 4943. The company would receive passive income from…
PLR 1126033: IRS approves a private foundation's scholarship grant procedure
The IRS approved a private foundation's procedures for awarding scholarships to academically qualified graduates of a redacted school who attend or plan to attend a college or university in a…
PLR 1126032: IRS approves a private foundation's college scholarship program
The IRS approved a private foundation's procedures for awarding scholarships to students who are U.S. citizens, live in a redacted location, attended high school in another redacted location, and…
PLR 1126031: IRS approves a fellowship program for graduate research
The IRS approved a private foundation's fellowship program for advanced doctoral students whose dissertations address the foundation's work concerning high-achieving students from lower-income…
IRS determination 1125046: Scholarship grant procedures approved
A private foundation requested advance approval for a scholarship program that would provide financial assistance to students at qualifying educational institutions. The IRS determined that the…
Determination 1122030: IRS approves a foundation's set-aside for relocating public statues
The IRS considered a private non-operating foundation's request to set aside income for relocating six public statues and, if necessary, commissioning a seventh statue. The project required…
Determination 1122029: IRS approves scholarship and therapeutic grants for children affected by abuse
The IRS approved a private foundation's procedures for making scholarships and specific objective grants to children with a history of abuse and neglect. Educational grants could fund study at…
PLR 1121031: IRS approved a private foundation's entrepreneurship grant program
The IRS approved a private foundation's procedures for grants to individuals who will study entrepreneurship and complete educational internships. The foundation will use a committee and objective,…
PLR 1121030: IRS approved a private foundation's high school scholarship program
The IRS approved a private foundation's scholarship procedures for high school students attending a redacted school and pursuing post-secondary education. The program selects recipients based on…
PLR 1120034: scholarship grant procedures approved under section 4945(g)(1)
The IRS approved a private foundation's proposed scholarship selection and grant procedures under IRC § 4945(g)(1). The foundation planned to award scholarships to graduating high school students…
PLR 1120033: employer-related scholarship program approved under section 4945(g)
The IRS approved a private foundation's employer-related scholarship program under IRC § 4945(g). A separate publicly supported organization would administer the program, select recipients, verify…
PLR 1119037: IRS approves private foundation scholarship procedures
The IRS approved a private foundation's procedures for awarding scholarships to eligible students in a defined community. The foundation proposed an objective selection process using academic…
PLR 1116029: IRS approved a private foundation’s artist grant program
The IRS approved a private foundation’s procedures for awarding grants to artists. The program supports innovative and interdisciplinary projects intended to affect communities through art. Grants…
IRS approved a private foundation scholarship program
The IRS reviewed a private foundation’s proposed scholarship program for academically qualified students with financial need. The program used an advisory committee, objective selection criteria,…
IRS approves a private foundation's scholarship grant procedures
The IRS approved a private foundation's procedures for awarding one-time scholarships to qualifying high school seniors. Applicants must live in the redacted county or attend a school there, enroll…
IRS approves employer-related scholarship programs
The IRS approved two employer-related scholarship options sponsored by a private foundation for children and other relatives of employees. The programs use an independent selection committee,…
IRS approves a fellowship program for investigative journalists
The IRS approved a private foundation's fellowship program for experienced international journalists. Fellows would receive training in investigative journalism, along with a stipend, travel…
PLR 1113040: IRS approves a charitable remainder trust reformation and finds no self-dealing
A married couple asked whether a state-court reformation of their charitable remainder trust would preserve the trust's status as a charitable remainder unitrust and avoid self-dealing excise taxes.…
PLR 1113039: IRS approves a private foundation's scholarship program
The IRS approved a private foundation's proposed scholarship program for students from a redacted geographic area who planned to attend qualifying educational institutions. The program used need and…
PLR 1113038: IRS approves a scholarship program for former residents of a care organization
The IRS approved a private foundation's scholarship program for academically qualified former residents of a redacted nonprofit care organization. Applicants had to meet age and residency…
PLR 1113037: IRS grants more time to dispose of excess business holdings
A private foundation received a donation representing all of the shares of a business and acknowledged that the shares created excess business holdings under IRC § 4943. The foundation described…
IRS determination 1111020: foundation receives a three-year set-aside extension
The IRS approved a charitable foundation's request for a 36-month extension to spend a previously approved set-aside for an online education project. The foundation had changed the project after…
IRS determination 1211029: IRS approves a private foundation's scholarship program
The IRS approved a private foundation's proposed scholarship program under IRC § 4945(g)(1). The program would identify students in public schools, provide scholarships based on objective…
PLR 1211028: IRS approves a private foundation's engineering scholarship programs
The IRS approved a private foundation's proposed scholarship programs for students from a redacted geographic area who are pursuing undergraduate engineering degrees. The programs use academic…
PLR 1211027: IRS approves scholarships for children needing specialized education and treatment
The IRS approved a private foundation's proposed scholarship program for children ages twelve through eighteen who need specialized educational or therapeutic settings because of addiction,…
IRS approved two private foundation scholarship programs
The IRS reviewed two proposed scholarship programs operated by a private operating foundation. One program would provide multi-year scholarships to graduating high school students, and the other…
IRS approved a private foundation grant program for student travel and study
The IRS reviewed a private foundation’s proposed grant program for recipients of an existing scholarship program. The proposed grants would support travel, study, or summer internships that improve…
PLR 1105053: Five-year extension granted to dispose of excess business holdings
The IRS considered a private foundation that received an unusually large bequest of stock and could not dispose of its excess business holdings within the initial five-year period without accepting…
PLR 1105052: Foundation set-aside approved as a qualifying distribution
The IRS approved a private foundation's plan to set aside funds for a public charity's multi-year conservation program. The program involved technical support, capacity building, and direct…
PLR 1105051: Road-improvement set-aside approved as a qualifying distribution
The IRS approved a private foundation's set-aside for a multi-year project to improve the only road serving a camp and related charitable facilities. The project included rebuilding the road,…
PLR 1104050: IRS approves a private foundation's scholarship procedures
The IRS approved a private foundation's procedures for awarding scholarships to individuals pursuing higher education in medicine or engineering. The proposed grants were limited to students meeting…
PLR 1104049: IRS approves employer-related scholarship procedures
The IRS approved a private foundation's procedures for scholarships sponsored for children and other relatives of the foundation's employees. A publicly supported scholarship organization would…
PLR 1104048: IRS approves a revised scholarship program
The IRS approved revised procedures for a private foundation's scholarship program for academically qualified high school graduates who need financial assistance. The foundation amended its trust…
PLR 1104047: IRS approves scholarships for students from an impoverished region
The IRS approved a private foundation's scholarship program for deserving secondary and post-secondary students from an impoverished region. The program considers academic performance, attendance,…
IRS approves a private foundation's leadership grant programs
The IRS approved a private foundation's procedures for grants to individuals under IRC § 4945(g)(3). The programs support leadership development, community capacity, and educational and…
PLR 1052020: IRS approved an employer-related scholarship program
The IRS approved a private foundation's employer-related scholarship program under IRC § 4945(g)(1). The program awards scholarships to children or relatives of employees through a competition based…
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.