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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Determination 1225015: IRS revokes charity exemption after records were not produced
The IRS revoked a charitable organization's exemption under IRC § 501(c)(3), effective January 1 of the redacted year. The organization had been formed to provide an after-school riding program for…
Determination 1225014: IRS revokes supporting-organization status after insider control of assets
The IRS revoked a nonprofit organization's exemption under IRC § 501(c)(3), effective January 1 of the redacted year. The organization had been recognized as a supporting organization under IRC §…
IRS denies VEBA status to an insurance trust
The IRS denied an insurance trust's request for recognition as a voluntary employees' beneficiary association under IRC § 501(c)(9). The trust made insurance coverage available to employees of…
IRS denies exemption to a cannabis dispensary
The IRS denied a nonprofit corporation's application for exemption under IRC § 501(c)(3). The organization distributed cannabis to members who had medical referrals, and it also provided related…
IRS denies exemption to four-unit condominium association
The IRS denied a mutual benefit corporation's application for exemption under IRC § 501(c)(4). The organization maintained the exterior of four condominium units and related common areas, funded by…
IRS denies social-welfare exemption to founder-controlled advocacy group
The IRS denied a founder-controlled advocacy organization's application for exemption under IRC § 501(c)(4). The organization described programs involving environmental action, law-enforcement…
IRS approves endowment units for a charitable remainder trust
The IRS ruled that a charitable remainder trust's contractual units in an organization's endowment would not generate unrelated business taxable income. The trust would have a contractual right to…
IRS denies exemption to a time-bank membership organization
The IRS issued a final adverse determination denying § 501(c)(3) exemption to a membership organization that operated a community time bank. Members exchanged services using units of time, and the…
PLR 1223011: IRS allows late homeowners association elections
The IRS granted a homeowners association 120 days to make late elections under IRC § 528 for two taxable years. The association's CPA firm had filed Forms 1120 instead of the required Forms 1120-H.…
IRS denies exemption to a grant-making organization that could not document charitable control
The IRS denied a foreign-grant-making organization's application for recognition under section 501(c)(3). The organization supported a foreign school but did not document its grant review, follow-up…
IRS revokes a business league's exemption after event-centered operations
The IRS revoked an organization's exemption under IRC § 501(c)(6), effective January 1 of a redacted year. The organization was created to facilitate a public motorcycle event, but the IRS found…
IRS revokes a social club's exemption after investment income exceeds 35 percent of receipts
The IRS revoked a social club's exemption under IRC § 501(c)(7), effective January 1 of a redacted year. The examination found that the club's investment income consistently exceeded 35 percent of…
IRS revokes a property-holding organization's section 501(c)(3) exemption
The IRS revoked an organization's exemption under IRC § 501(c)(3), effective January 1 of a redacted year. The organization held title to a building and collected rent for another entity, but…
IRS revokes a charity's exemption after personal expenses and inadequate records
The IRS revoked an organization's exemption under IRC § 501(c)(3), effective January 1 of a redacted year. The examination found that the organization paid personal expenses on the president's…
IRS revokes a charity's exemption after it ceases operations and fails to provide records
The IRS revoked an organization's exemption under IRC § 501(c)(3), effective January 1 of a redacted year. The organization did not provide information requested during an examination, appeared to…
IRS revokes an inactive charity's exemption
The IRS revoked an organization's exemption under IRC § 501(c)(3), effective July 1 of a redacted year. An examination found that the organization had been inactive and had no operations or regular…
IRS denies exemption to a fee-based fishing and retreat camp
The IRS denied an organization's application for exemption under IRC § 501(c)(3). The organization operated a fishing camp and retreat center that charged fees for lodging, meals, fishing, outdoor…
IRS approves a union's in-house pharmacy benefit program
The IRS ruled that a labor organization could operate its pharmacy benefit program through a wholly owned disregarded limited liability company without creating an unrelated trade or business. The…
IRS approves exempt-purpose transfers within a retirement-community system
The IRS ruled that a tax-exempt retirement community could transfer or share assets, personnel, facilities, and services with its supporting organization without jeopardizing its exemption. The…
IRS approves a new continuing-care retirement community
The IRS ruled that an existing public charity would remain exempt under IRC § 501(c)(3) and remain publicly supported under § 509(a)(2) after changing its name, moving its planned location, and…
IRS approves shared services among retirement-community organizations
The IRS ruled that a supporting organization could share assets, personnel, facilities, and services with the retirement communities it supported without creating unrelated business income. The…
PLR 1221030: IRS approves a VEBA's expansion to state government employees
The IRS ruled that a voluntary employees' beneficiary association could expand its eligible membership from public-school employees to employees of any governmental unit in the same state without…
Determination 1221029: IRS revokes political training group's § 501(c)(4) exemption
The IRS revoked an organization's recognition as exempt under IRC § 501(c)(4) after finding that its training program primarily served a political party and its candidates. The organization trained…
Determination 1221028: IRS revokes women's political leadership group's § 501(c)(4) exemption
The IRS revoked an organization's recognition as exempt under IRC § 501(c)(4) after finding that its political leadership training program primarily served a political party and its candidates. The…
Determination 1221027: IRS revokes political leadership training group's § 501(c)(4) exemption
The IRS revoked an organization's recognition as exempt under IRC § 501(c)(4) after finding that its political leadership training program primarily served a political party and its candidates. The…
Determination 1221026: IRS revokes political leadership group's § 501(c)(4) exemption
The IRS revoked an organization's recognition as exempt under IRC § 501(c)(4) after finding that its political leadership training program primarily served a political party and its candidates. The…
Determination 1221025: IRS revokes women's political leadership group's § 501(c)(4) exemption
The IRS revoked an organization's recognition as exempt under IRC § 501(c)(4) after finding that its political leadership training program primarily served a political party and its candidates. The…
PLR 1221024: IRS approves museum, assistance, vending, and trademark rulings
The IRS ruled that a tax-exempt foundation operating a sports history museum could run a financial-assistance program for eligible members of an affiliated coaching association without jeopardizing…
Determination 1221023: IRS denies exemption to carbon-offset certification organization
The IRS denied exemption under IRC § 501(c)(3) to an organization that planned to certify service-company projects as carbon neutral and resell carbon offsets purchased from a for-profit company.…
Determination 1221022: IRS denies exemption to a small religious organization
The IRS denied a small religious organization's application for exemption under IRC § 501(c)(3). The organization described worldwide ministry, food-bank services, GED scholarships, and worship…
Final adverse determination: IRS denies Section 501(c)(6) exemption to a referral organization
The IRS denied a referral and networking organization's application for exemption under IRC § 501(c)(6). The organization promoted members' businesses through referrals, a searchable directory,…
PLR 1220005: State educational instrumentality qualifies for deductible contributions
The IRS ruled that an organization created by a state legislature to support public schools serving students with vision and hearing impairments is an instrumentality of the state. The organization…
IRS revokes a debt-management organization's tax exemption
The IRS issued a final adverse determination revoking a debt-management organization's exemption under IRC § 501(c)(3). The organization primarily solicited and enrolled consumers in debt-management…
Determination 1219032: IRS denies section 501(c)(7) exemption to a craft guild
The IRS denied tax exemption to a nonprofit craft guild that held public craft shows and paid members the proceeds from their product sales. The organization argued that its shows, meetings,…
PLR 1219031: IRS approves a regulated electricity market counterparty structure
The IRS considered an independent system operator's plan to become the central counterparty for transactions in its regulated wholesale electricity markets. The operator would take title to the…
IRS denies section 501(c)(4) exemption to a facility rental organization
The IRS denied section 501(c)(4) exemption to a nonprofit that operated a large facility with office, conference, meeting, and lodging rentals. The organization rented to tax-exempt groups,…
IRS denies section 501(c)(3) exemption to a family trust
The IRS denied section 501(c)(3) exemption to a family trust established to pay health, education, welfare, and religion expenses for named relatives of the grantor. The trust agreement did not…
IRS denies section 501(c)(3) exemption to a grant conduit for a jewelry business
The IRS denied section 501(c)(3) exemption to a nonprofit formed to obtain grant funding for a for-profit jewelry business. The proposed nonprofit planned to send about 5 percent of any grant to…
IRS revokes a section 501(c)(3) organization's exemption for private spending
The IRS revoked a section 501(c)(3) organization's exemption after finding that its president used the organization's bank account for personal expenses and controlled its funds without adequate…
IRS revokes a student-housing organization's section 501(c)(3) exemption
The IRS revoked a student-housing organization's section 501(c)(3) exemption after concluding that its primary activity was operating and maintaining a chapter house for a university fraternity. The…
IRS denies exemption to a small synagogue and would classify it as a private foundation
The IRS denied section 501(c)(3) exemption to a small synagogue that operated in space provided by another congregation. The applicant had few documented activities, no board meeting minutes,…
PLR 1219024: IRS approves an international reorganization for an educational program
A public charity that teaches youth about work readiness, entrepreneurship, and financial literacy asked the IRS about a reorganization separating its U.S. and international operations. The charity…
IRS determination 1218041: Child-care organization denied section 501(c)(3) exemption
The IRS denied an organization’s application for recognition as a section 501(c)(3) exempt organization, effective from its incorporation date. The organization operated a daycare and afterschool…
IRS revokes an arts organization's tax-exempt status for commercial consulting activities
The IRS revoked an arts organization's exemption under IRC § 501(c)(3). The organization primarily provided fee-based consulting, management, marketing, and fundraising services to artists and arts…
IRS revokes an organization's exemption after it failed to provide required information
The IRS revoked an organization's exemption under IRC § 501(c)(3). The organization did not protest the proposed modification of its non-private-foundation status, agreed by signing Form 6018, and…
IRS denies exemption to an organization that did not establish its charitable operations
The IRS issued a final adverse determination that a proposed housing-counseling organization did not qualify for exemption under IRC § 501(c)(3). The organization had not developed enough detail…
IRS revokes exemption from a veterans organization that operated a public bar
The IRS revoked the federal tax exemption of a veterans organization under IRC § 501(c)(19). The organization operated a bar that was open to the general public and did not maintain a legitimate…
IRS revokes exemption from an inactive charitable organization
The IRS revoked an organization's exemption under IRC § 501(c)(3), effective after the organization became inactive. The IRS found that the organization did not satisfy the operational test, lacked…
IRS proposes revoking exemption from a professional association over private inurement
The IRS proposed revoking a professional association's exemption under IRC § 501(c)(6). The examination report said that the organization lacked meaningful membership support and received most of…
IRS denies exemption to a captive insurance company serving community clinics
The IRS denied exemption under IRC § 501(c)(3) to a proposed nonprofit captive insurance company serving community healthcare clinics. The organization’s articles authorized it to provide insurance…
IRS denies exemption to a risk-retention captive insurer for community clinics
The IRS denied exemption under IRC § 501(c)(3) to a risk-retention captive insurance company serving nonprofit community clinics. The organization’s articles authorized it to provide insurance, and…
IRS rules endowment unit contracts will not create unrelated business taxable income
The IRS ruled that an educational organization’s proposed contractual units for charitable remainder trusts would not generate unrelated business taxable income to the organization. The organization…
IRS rules charitable remainder trust units will not create unrelated business taxable income
The IRS ruled that a proposed contractual unit arrangement for charitable remainder trusts would not generate unrelated business taxable income to the trusts under the stated facts. The arrangement…
IRS revokes an exempt organization’s section 501(c)(3) status after finding substantial non-exempt activity
The IRS revoked an organization's recognition under IRC § 501(c)(3). The organization said it provided debt consolidation and credit counseling to financially distressed people, but the examination…
IRS revokes an organization’s exemption after finding private benefit in Proposition 65 litigation
The IRS revoked an organization’s recognition under IRC § 501(c)(3), effective January 1, 2006. The organization pursued Proposition 65 litigation and said the lawsuits served the public interest,…
IRS denies a charter school’s request to avoid Form 990 filing
The IRS denied a charter school’s request to be excepted from filing Form 990 as a governmental affiliate. The school operated under a charter approved by a school district, but its board was…
IRS approves restructuring of a tax-exempt organization into association, union, and foundation entities
The IRS approved two parts of a proposed restructuring by a tax-exempt organization. The organization planned to transfer its charitable assets and liabilities to a new § 501(c)(3) public charity,…
IRS denies exemption to a civil-rights organization that lacked operational detail and served private interests
The IRS finalized its denial of tax-exempt status to an organization formed to promote access to justice, education, medical care, and civil-rights leadership. The organization planned to raise…
IRS denies exemption to an umpire organization that primarily served its members
The IRS denied exemption to an organization that recruited and trained baseball umpires and arranged paid assignments for schools, parks, and youth leagues. The organization’s members received the…
IRS denies exemption to a foreclosure-consulting organization that operated commercially
The IRS denied exemption to an organization that counseled homeowners facing foreclosure and negotiated loan modifications with lenders. The organization charged fees, used a for-profit referral…
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.