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 stipends for low-income students in an after-school arts program
A private foundation proposed an after-school fine-arts program for high school juniors and seniors from low-income households. Participants would study with art professionals, complete individual and…
Advance approval of amended scholarship-grant procedures for a private foundation
A private foundation runs a scholarship program and had it approved by the IRS once before. It made three changes and asked the IRS to re-approve its grant-making procedures under Section 4945(g). Adv…
Advance approval of a foundation's scholarship and educational-grant procedures
A private foundation asked the IRS to pre-approve two individual-grant programs tied to promoting a particular philosophy: a scholarship program under Section 4945(g)(1) and an educational-grant progr…
Approval to set aside a matching grant for a historic-building restoration
A private foundation wanted to earmark money now for a project it will pay for later. Private foundations must give away a minimum amount each year, and cash actually paid out counts toward that requi…
Advance approval of an employer-related scholarship program for employees' children
A private foundation runs a scholarship program for the children and dependents of employees at three related companies and asked the IRS to pre-approve its selection procedures under Section 4945(g).…
Advance approval of scholarship procedures for a trust converted from a student-loan fund
A private foundation set up as a charitable trust asked the IRS to pre-approve its scholarship selection procedures under Section 4945(g). The trust originally made low-cost student loans, but it got …
Advance approval of a scholarship program that recruits students through youth charities
A private foundation asked the IRS to pre-approve the selection procedures for a scholarship program it runs. Advance approval matters because a private foundation that pays a grant to an individual f…
Advance approval of a foreign scholarship program for underprivileged students
A private foundation asked the IRS to pre-approve the selection procedures for a scholarship program aimed at economically disadvantaged students in a rural area of a foreign country. Advance approval…
IRS approves a private foundation's employer-related scholarship procedures
A private foundation asked the IRS to approve a scholarship program for children of employees of an affiliated company. An experienced public charity will administer the program, and its staff will fo…
QTIP trust may reimburse an estate with stock without private-foundation self-dealing
A private foundation was a residuary beneficiary of a trust whose assets were included in a deceased spouse's taxable estate. The trust instrument and a probate-court order required the trust to reimb…
IRS approves scholarships from preschool through college plus enrichment grants
A private foundation proposed renewable scholarships for at-risk and underserved students to attend preschool through college. It also proposed educational grants for tutoring and subject-matter enric…
IRS approves a nationwide college scholarship for young women with financial need
A private foundation proposed a nationwide scholarship competition for young women pursuing college education who demonstrate financial need. Applicants must meet academic and enrollment requirements …
IRS approves grants and professional mentoring for young playwrights
A private foundation proposed an educational grant initiative for public high school students in one city who submit original one-act plays. Selected young playwrights would receive cash awards, indiv…
IRS approves global leadership grants and scholarships for teenagers
A private foundation proposed a global competition to identify teenagers with leadership potential from diverse regions and backgrounds. Winners would attend a residential leadership program, join a l…
IRS approves musician residency grants for artistic development
A private foundation proposed a residency grant program for individual musicians and bands. Grantees would receive a stipend, housing, workspace, equipment, instruction, and performance opportunities …
IRS approves leadership grants for day-school administrators
A private foundation proposed grants for administrators at day schools with a specified educational and religious mission. Fellows would complete summer leadership training and a year-long school impr…
Private foundation gets five more years to dispose of illiquid company stock
A private foundation received company stock worth more than twice its prior total assets, creating excess business holdings under IRC § 4943. During the initial five-year disposal period, an investmen…
IRS approves a private foundation's set-aside to buy land and build transitional housing for abused women
Private foundations normally have to pay out a minimum amount each year, but they can "set aside" money for a specific long-term project and still get credit for it as a qualifying distribution, provi…
IRS approves a private foundation's college scholarship procedures for high-achieving young women with financial need
A private foundation proposed renewable college scholarships for high-achieving young women who attended high school in a specified city, planned to attend an accredited four-year institution in the i…
IRS approves a private foundation's college scholarship procedures
A private foundation proposed scholarships for graduating high school students from disadvantaged areas who showed financial need and strong academic performance. Awards would cover tuition and relate…
IRS approves a charitable lead trust's nonvoting interest in a note-holding LLC
A charitable lead unitrust was entitled to receive part of a revocable trust's residue, which included a promissory note owed by a disqualified person. A direct transfer of that note to the charitable…
IRS approves direct scholarships for public-service graduate fellows
A private foundation supports graduate students at partner universities who commit to federal government service for at least three of their first seven years after graduation. The foundation historic…
A private foundation's international art grants count as qualifying distributions and aren't self-dealing, despite a director's earlier art purchase
A private foundation that promotes the arts wants to fund a foreign national arts organization ("X"), which will in turn grant money to overseas museums and galleries to buy and publicly display works…
IRS pre-approves an art-residency foundation's grant procedures, so its artist honoraria aren't taxable expenditures
A private foundation runs a residency program that gives visual artists and art professionals time, space, and a modest honorarium to work on their projects. Because private foundations owe an excise …
Advance approval of a foundation's art-scholarship grant procedures
A private foundation runs a scholarship program for graduating seniors at one local high school who have shown a commitment to the arts, paying tuition directly to the college where they study art. Be…
Foundation's grants for electric buses are qualifying distributions, not self-dealing with its utility founder
A private foundation was created and is funded entirely by a regulated electric and gas utility, which makes the utility a "disqualified person" the foundation generally cannot benefit. The foundation…
202032006: IRS approves a private foundation's procedures for five educational grant programs
A private foundation sought advance approval for five educational grant programs serving students, faculty, artists, writers, and environmental researchers connected with an eleven-institution consort…
202032005: IRS approves a private foundation set-aside for a historic building restoration
A private foundation requested approval to set aside funds for a matching grant to an organization that owned and maintained a historic building. The recipient planned to restore the building's histor…
IRS approves a foundation's cybersecurity grant procedures
A private foundation proposed a program making grants to individuals who would develop technical solutions to complex cybersecurity problems and contribute to knowledge in cybersecurity and artificial…
IRS approves a foundation's college scholarship procedures
A private foundation proposed a scholarship program for high school seniors and incoming college students attending a U.S. community college, trade or vocational school, or four-year institution. Appl…
IRS approves a foundation's set-aside for a historic restoration grant
A private foundation planned a matching grant to a public charity for rehabilitating and restoring a historic residence, including accessibility and code-compliance improvements. The grant would cover…
IRS approves a foundation's need-based scholarship procedures
A private foundation operated a scholarship program for study at U.S. educational institutions, with funds available for tuition, books, supplies, and room and board. Applicants had to provide transcr…
IRS approves agricultural scholarships for women from farmworker families
A private foundation proposed scholarships for daughters or transgender females from families working in agriculture who would enter a two-year agriculture and natural-resources degree program at a sp…
IRS approves a set-aside for a historic-site matching grant
A private foundation planned a matching grant to a governmental unit for restoring a property listed on the National Register of Historic Places. The project included historic restoration, safety work…
Conservation land's exempt-use value is excluded from a foundation's investment return
A private foundation owned conservation land containing threatened plants, endangered bird habitat, native forests, and other natural resources protected by a conservation easement. It managed the pro…
A private foundation may set aside funds for a planned art museum
A private foundation planned to create a museum for contemporary studio art glass in a recently purchased building. The artwork was tied up in an estate, and renovating the building or finding an alte…
A foundation's artist and musician grant procedures satisfy section 4945
A private foundation proposed two programs offering grants and awards to artists and musicians. One program would fund projects intended to develop artistic or musical careers, while the other would r…
A foundation may make forgivable educational loans to future local medical providers
A private foundation proposed a low-interest educational loan program for students pursuing healthcare careers. Recipients would commit to return to a specified community and work as medical providers…
IRS approves grants for volunteer public safety training
A private foundation proposed educational grants to help volunteer public safety service providers obtain the training, education, and skills needed for their work. Eligible applicants would generally…
IRS approves scholarships for graduates of rural high schools
A private foundation proposed a scholarship program for graduates of three rural high schools attending qualifying post-secondary institutions. Awards would cover remaining attendance costs after fami…
Post-annuity trust distributions and expense reimbursement are not self-dealing
A charitable lead annuity trust paid an increasing annuity to a charity whose interest was later divided equally between two foundations. After the final annuity payments, the surviving-spouse trustee…
IRS approves need-based scholarships for sports, arts, and education
A private foundation proposed scholarships for education and training of youth involved in soccer and other sports and for underprivileged people developing talents in the arts, education, or athletic…
IRS approves a four-year youth coaching and scholarship program
A private foundation and a co-funder designed a four-year program for high school students combining character development, individualized coaching, entrepreneurial problem-solving, career exposure, c…
Foundation may fund relocation and housing for STEM interns
A private foundation proposed stipends helping underserved and underrepresented college students pay relocation and housing costs for STEM internships. Eligible students would be rising sophomores, ju…
Foundation's artist residency grants receive advance approval
A private foundation proposed an artist residency program providing time, space, housing, and financial support for artists to create work and exchange ideas. Recipients would generally receive a week…
Foundation scholarship procedures received advance approval
A private foundation proposed scholarships for financially needy international students graduating from high schools in a specified city and attending college in the United States. Applicants would be…
Foundation scholarship procedures received advance approval
A private foundation proposed scholarships for financially needy students committed to succeeding at colleges, trade schools, technical schools, or similar postsecondary institutions in the United Sta…
Museum expansion set-aside approved as a qualifying distribution
A private foundation planned to expand and improve an art museum facility that it owned and leased to an exempt museum operator. The project required more funds than the foundation's current annual in…
Scholarship and educational grant procedures approved
A private foundation requested advance approval for three need-based scholarship programs and a broader educational grant program. The scholarships covered college, advanced-degree, or specialized pri…
Historic building restoration set-aside approved
A private foundation proposed a grant to a public charity restoring a historic building as a community center for culture, education, and neighborhood revitalization. The grant would fund about one-th…
IRS approves a private foundation's scholarship procedures
A private foundation proposed scholarships for high school seniors who belong to a tax-exempt financial cooperative and plan to attend an accredited college, university, community college, vocational …
Foundation may divide its assets among related foundations and terminate
A private foundation whose directors disagreed about its operation proposed dividing all of its assets evenly among several existing or newly formed private foundations controlled by the same people. …
IRS approves educational grants for courses supporting academic dialogue
A private foundation proposed educational grants for selected people affiliated with a named organization to take courses about specified philosophies, practices, and academic culture. Applicants had …
IRS approves civic-education grants for teachers
A private foundation proposed annual one-time grants to K-12 teachers for classroom units using public deliberation or deliberative teaching about important national issues. Applicants had to demonstr…
QTIP trust settlement received favorable transfer-tax rulings
A surviving spouse and bank trustee settled extensive litigation by terminating an irrevocable QTIP trust and two marital QTIP trusts. The spouse would receive a support distribution plus the actuaria…
QTIP trust termination settlement received favorable rulings
A surviving spouse and bank trustee proposed to end an irrevocable QTIP trust and two marital QTIP trusts under a court-approved settlement. The spouse would receive a support payment and cash equal t…
QTIP settlement termination received favorable tax treatment
A surviving spouse and trustee settled trust litigation by proposing to terminate an irrevocable QTIP trust and two marital QTIP trusts. The spouse would receive a support distribution and the actuari…
Court-approved QTIP trust settlement received favorable rulings
A surviving spouse and bank trustee sought rulings before completing a court-approved settlement that would terminate an irrevocable QTIP trust and two marital QTIP trusts. The spouse would receive a …
QTIP trust settlement approved for transfer-tax purposes
A surviving spouse and trustee proposed a court-approved settlement ending an irrevocable QTIP trust and two marital QTIP trusts. The spouse would receive a support distribution and the present value …
Scholarship and educational grant procedures approved
A private foundation proposed scholarships and educational grants for graduating seniors from a specified school who had overcome financial, family, illness, or disability-related hardship. Awards cou…
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.