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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Private foundation loses exemption for self-dealing and nonexempt activity
A private foundation formed to operate a residential center for people with autism failed for years to carry out that purpose. The examination report found that the founder's adult child was the…
Global education program preserves exemption and avoids unrelated business income
A public charity operated educational programs focused on global business and leadership. It proposed replacing one program with a multi-country program managed by a foreign nonprofit controlled by…
Planned religious community denied exemption for private benefit
An organization sought section 501(c)(3) status as a church while planning a residential, recreational, educational, and retreat community on land owned by its founder. Its religious services…
Exemption revoked for political campaign intervention
A section 501(c)(3) organization published website articles and newsletters and sent fundraising solicitations containing repeated statements supporting or opposing candidates in presidential and…
Fundraising training organization denied exemption as commercial
A nonprofit sold memberships that included books, digital materials, newsletters, fundraising instruction, and help designing and implementing fundraising programs. Its president owned or claimed…
Foreign cooperative institution denied credit-union exemption
A nonprofit financial institution organized in a foreign country applied for exemption as a state-chartered credit union under section 501(c)(14). It translated the foreign law governing its…
VEBA may provide limited health benefits to domestic partners
A tax-exempt voluntary employees' beneficiary association asked about health reimbursement arrangement benefits for employees' domestic partners. The IRS concluded that coverage for qualifying…
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,…
University youth programs treated as educational activities
A land-grant university asked whether its youth Club activities would be treated as part of the university’s educational operations and whether designated contributions could be deductible. The IRS…
VEBA may add non-union employees of member organizations
A voluntary employees’ beneficiary association asked whether it could add non-union common-law employees of member organizations to its health-benefit plan. The IRS concluded that the proposed…
Exemption denied for a community-organizing support organization
The IRS denied tax-exempt status under IRC § 501(c)(3) to an organization formed to train, fund, and support community-organizing groups. The organization planned to provide leadership development,…
Digital-resource nonprofit denied exemption
The IRS denied IRC § 501(c)(3) exemption to an organization formed to preserve and develop digital resources with scientific and educational content. The organization planned to raise donations and…
Exempt status revoked after dissolution and inactivity
The IRS proposed revoking an organization's IRC § 501(c)(3) exemption after the original entity dissolved and a new organization began using the dissolved entity's employer identification number.…
Housing rehabilitation program denied exemption
The IRS denied IRC § 501(c)(3) recognition to an organization that planned to buy, rehabilitate, and sell single-family homes to low- and moderate-income buyers. The organization did not identify…
Exemption revoked for a gaming operator with private-benefit concerns
The IRS revoked an organization's IRC § 501(c)(3) exemption after finding that its primary activity was operating weekly games and that its charitable donations were insubstantial compared with its…
IRS revokes an association's tax-exempt status after finding its activities were substantially social
The IRS issued a final adverse determination that an association did not qualify for exemption under IRC § 501(c)(3), effective January 1, 20XX. The IRS found that a substantial part of the…
IRS denies exemption to a proposed multi-employer supplemental unemployment benefit trust
The IRS denied tax-exempt status to a proposed trust seeking classification under IRC § 501(c)(17) as a supplemental unemployment benefit trust. The trust was designed to provide benefits to…
Medical-provider association denied tax exemption
The IRS considered a medical-provider association's application for exemption under IRC § 501(c)(6). The association negotiated managed-care contracts, credentialed members, arranged discounts, and…
Referendum committee denied section 501(c)(4) exemption
The IRS considered a referendum committee's application for exemption under IRC § 501(c)(4). The committee was formed and funded by one limited liability company, which also controlled its…
Religious consulting and travel organization denied exemption
The IRS considered a religious organization's application for exemption under IRC § 501(c)(3). The organization provided consulting services to congregations and arranged religious heritage and…
Religious congregation denied exemption over president's building lease
The IRS considered a religious congregation's application for exemption under IRC § 501(c)(3). The congregation leased an unusable building from its president, paid most of its revenue toward…
Public higher-education organization qualifies as a state instrumentality
The IRS ruled that a redacted organization operating as a public institution of higher learning is an instrumentality of its state. The organization was established by state law, served a…
IRS revokes an organization's section 501(c)(3) status
The IRS issued a final adverse determination revoking an organization's recognition as exempt under IRC § 501(c)(3), effective on the stated date. The determination says the organization operated a…
IRS revokes an organization's section 501(c)(3) status
The IRS issued a final adverse determination revoking an organization's recognition as exempt under IRC § 501(c)(3), effective on the stated date. The letter says the organization was not operated…
VEBA may use remaining trust assets to pay current health insurance benefits
The IRS considered a voluntary employees’ beneficiary association that planned to terminate its insurance coverage and liquidate its remaining assets. After paying expenses and liabilities, the…
Dissolving VEBA may preserve exemption and avoid unrelated business income tax
The IRS considered a self-insured VEBA that planned to terminate after several significant claims and use its excess assets to continue providing medical and dental benefits. The trust proposed to…
IRS denies exemption to a raffle-based outdoor excursion organization
The IRS denied tax-exempt status under IRC § 501(c)(3) to an organization that planned to raise money through online raffles for hunting and fishing excursions and outdoor equipment. The…
IRS revokes an organization's tax-exempt status for commercial operations and missing records
The IRS revoked an organization's recognition as exempt under IRC § 501(c)(3), effective on the specified date. The organization had described itself as presenting multimedia art and educational…
IRS denies exemption to a member-funded medical aid plan seeking social welfare status
The IRS denied an unincorporated association's application for exemption under IRC § 501(c)(4). The association provided medical expense reimbursements only to members of a particular faith who paid…
IRS denies exemption to a fee-based health care cooperative serving its members
The IRS denied a nonprofit health care cooperative's application for exemption under IRC § 501(c)(3). The organization arranged discounted medical services, physician retainer plans, and insurance…
IRS declines to limit the retroactive revocation of an organization's exemption
This Technical Advice Memorandum considered whether the IRS should limit the retroactive effect of revoking a taxpayer's exemption under IRC §§ 501(c)(3) and 7805(b). The taxpayer had represented…
IRS approves a cemetery's plan to operate a funeral-home subsidiary
A tax-exempt cemetery company asked whether it could form a wholly owned, for-profit subsidiary to own and operate a funeral home. The IRS approved the plan because the subsidiary would be…
IRS revokes a social club's tax exemption for excessive public and nonmember activity
The IRS revoked a social club's exemption under section 501(c)(7). The club regularly opened events to the general public, and its nonmember receipts exceeded the limits described in Public Law…
IRS rules that endowment unit contracts will not create unrelated business taxable income
An educational charity planned to issue contractual units tied to the value and distributions of its endowment to charitable remainder trusts for which it served as trustee and remainder…
IRS rules that charitable remainder trusts' endowment units will not create UBTI
An organization that served as trustee and charitable remainder beneficiary of trusts planned to issue contractual units tied to its endowment. The IRS ruled that issuing the units, making or…
IRS rules that stream mitigation credit sales are not unrelated business income
A nonprofit environmental organization operated a nature center and planned to create and sell stream mitigation credits. The IRS ruled that the organization's stream restoration and mitigation-bank…
Social-justice organization denied section 501(c)(3) exemption
An organization seeking recognition under section 501(c)(3) described social-justice research, education, grants, and community mobilization. It shared staff, facilities, governance ties, and…
Broadband-access organization denied section 501(c)(3) exemption
The IRS considered an organization formed to expand broadband internet service in underserved and unserved areas. The organization planned to organize community stakeholders, negotiate access to…
Exemption revoked after an organization failed to provide requested records
The IRS revoked an organization's section 501(c)(3) exemption after the organization did not provide requested information about its activities, records, and dissolution. The examination materials…
Healthcare-system parent was not a qualified educational organization
A parent organization for an integrated healthcare system asked whether it was a qualified educational organization under section 170(b)(1)(A)(ii). That status would have allowed an exception from…
Liquidation of unused IPv4 addresses will not create unrelated business income
A tax-exempt supporting organization held several million unused IPv4 address rights that it had received decades earlier for its exempt telecommunications and research activities. It planned to…
IRS denies exemption to a fundraising organization serving a for-profit club network
The IRS denied exemption to an organization that raised money for a for-profit youth sports club network and credited fundraising proceeds to club member fees. The organization's activities funded…
IRS revokes a foundation's exemption after private benefits and excess benefit transactions
The IRS revoked a foundation's federal income tax exemption after an examination of its activities and expenditures. The foundation was formed to support people affected by autism and Alzheimer's…
IRS declines to limit retroactive revocation after material operational changes
A tax-exempt organization said it would provide financial education, counseling, and debt-management services for people with low or moderate incomes. The IRS examination found that the organization…
IRS declines retroactive relief after commercial debt-management operations
A tax-exempt organization represented that it would educate the public about budgeting and credit, provide counseling, and administer debt-management plans for people with serious financial…
IRS declines retroactive relief after debt-management fees and undisclosed related trustee
A nonprofit organization represented that it would provide free credit counseling, budgeting help, and debt-management assistance to financially distressed people. The IRS examination found that the…
IRS denies exemption to a Bible translation publisher using a commercial model
The organization sought section 501(c)(3) exemption to oversee the production, publication, and distribution of a Bible translation and related materials. It planned to publish through a for-profit…
IRS denies exemption to a mobile fundraising and marketing platform
The organization proposed a mobile application that would let users direct merchant-sponsored funds to schools and other charities. The IRS found that the program primarily provided marketing and…
IRS approves a trade association's tournament activities as related to its exempt purpose
The IRS considered whether a tax-exempt trade association could reacquire and operate a set of major sporting events. It ruled that operating the events would not harm the association's exemption…
IRS respects taxable subsidiaries as separate entities from an exempt health maintenance organization
A tax-exempt health maintenance organization planned to create two taxable subsidiaries and transfer employees and administrative contracts to one of them. The IRS considered whether the…
IRS denies exemption to a supplemental unemployment benefit trust
The IRS denied tax-exempt status to a trust formed to provide supplemental unemployment benefits. The trust was sponsored by one corporation, and the record showed that only one employee was covered…
IRS revokes exemption after an organization stopped responding and filing required returns
The IRS revoked an organization's federal tax exemption under IRC § 501(c)(3), effective as of the stated date in the final letter. The organization did not provide information requested during an…
IRS revokes a social club's exemption for excessive nonmember income
The IRS revoked a social club's federal tax exemption under IRC § 501(c)(7), effective January 1 of the stated year. The examination found that the club's nonmember income exceeded the applicable…
IRS revokes exemption after an organization failed to respond to examination requests
The IRS revoked an organization's federal tax exemption under IRC § 501(c)(3), effective January 1 of the stated year. The organization did not respond to repeated requests to inspect its books,…
IRS revokes exemption for failure to provide records and file returns
The IRS revoked an organization's federal tax exemption under IRC § 501(c)(3), effective July 1 of the stated year. The organization failed to produce records showing that it operated exclusively…
IRS proposes revocation after a charity remained inactive
The IRS proposed revoking an organization's federal tax exemption under IRC § 501(c)(3). The organization had not operated for more than three years and had not filed required returns. Its…
IRS revokes exemption after a charity's activities served private interests
The IRS revoked an organization's federal tax exemption under IRC § 501(c)(3), effective January 1 of the stated year. The organization was formed to operate foster homes, but the IRS concluded that…
IRS revokes exemption after a charity ceased all activities
The IRS revoked an organization's federal tax exemption under IRC § 501(c)(3), retroactive to the redacted effective date. The organization had provided housing to low- and moderate-income families…
IRS treats an educational website as a periodical for advertising cost allocation
An educational private operating foundation replaced its print magazine with a free website containing archived and regularly updated editorial content. The foundation also received advertising…
IRS revokes a small insurance company's section 501(c)(15) exemption
The IRS revoked an organization's exemption under IRC § 501(c)(15), which applies to certain small insurance companies. The examination report concluded that the organization's gross receipts,…
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.