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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Scholarship procedures for women studying the arts approved
A private foundation proposed scholarships for female students pursuing music, drama, visual arts, and related fields at accredited institutions in a specified area. Applicants had to be U.S. citizens…
Fellowship and alumni grant procedures approved
A private foundation proposed fellowships for young U.S. citizens and permanent residents to spend nine to twelve months abroad pursuing individualized religious, cultural, educational, and leadership…
Domestic and international scholarship procedures approved
A private foundation proposed two need-based scholarship programs for low-income high school seniors. One would support students connected with a specified church, while the other would support studen…
Revolving educational loan procedures approved
A private foundation proposed a revolving educational loan program for needy and deserving students under age 23 who lived in a specified area. Loans could support study at U.S. trade, technical, prof…
IRS approves county-based scholarship procedures
A private foundation requested advance approval for a scholarship program serving high school seniors and community college transferees who lived in a specified county and participated in an approved …
Private foundation scholarship program receives advance approval
A private foundation requested advance approval for a scholarship program serving high school seniors and community college transferees who lived in a specified county and participated in an approved …
IRS approves public-service fellowship procedures
A private foundation proposed a fellowship for university students committed to public service. Rather than cash, selected fellows would receive lodging, counseling, and supplemental liberal-arts educ…
IRS approves nonprofit-board fellowship procedures
A private foundation proposed a year-long program of seminars and a retreat to train public-charity board members in governance, fiduciary duties, fundraising, meeting facilitation, leadership, and or…
IRS approves multi-year facility-project set-aside
A private foundation undertaking a multi-year scientific-research facility upgrade proposed setting aside funds to secure fabrication pricing and demonstrate commitment while raising the remaining pro…
IRS approves regional-study scholarship and grant procedures
A private foundation proposed scholarships for qualifying students and grants for projects focused on two redacted geographic regions. Applicants would be selected using objective criteria, insiders a…
IRS approves innovative-teaching award procedures
A private foundation proposed an award program for full-time teachers who submit experience-based proposals for innovative classroom methods and improved student services. An independent review board …
IRS approves scholar and professional fellowship procedures
A private foundation proposed a fellowship program for promising or accomplished scholars and professionals in fields including the humanities, education, journalism, the arts, medicine, science, and …
IRS approves educational exam-voucher grant procedures
A private foundation proposed an educational grant program that would issue exam vouchers and reimburse testing-center costs for learners who completed course content and met a stated score threshold.…
IRS approves a five-year scientific grant set-aside
A private foundation proposed setting aside funds for grants to organizations conducting research expected to advance chemistry and life sciences. The grants would support the purchase and operation o…
IRS approves scholarship and education-support grants
A private foundation proposed two grant programs for students and recent graduates. One would fund postsecondary tuition, related expenses, and room and board, while the other would cover education-co…
IRS approves community and employee-child scholarships
A private foundation proposed one scholarship program for graduating seniors in a local area and another for children of a company's full-time employees. Both programs would use academic achievement, …
IRS approves entrepreneurial student fellowship procedures
A private foundation proposed a one-year fellowship for full-time undergraduate and graduate students pursuing independent entrepreneurial projects. Projects could involve nonprofit or for-profit work…
IRS approves renewable scholarships for low-income students
A private foundation proposed scholarships for low-income college students who lived in a specified local area. Awards could cover tuition, books, supplies, and room and board, and applicants had to m…
IRS approves set-aside for historic university building restoration
A private foundation proposed setting aside funds for the rehabilitation and repair of an uninhabitable historic building that a public university planned to use. The grant would cover about one-third…
IRS approves college scholarships for music-program students
A private foundation proposed college scholarships for high-need students who had participated for at least three years in nonprofit music education programs supported by the foundation. Students had …
IRS approves scholarships for local high school seniors
A private foundation proposed scholarships for graduating seniors at two local high schools. Different awards would consider criteria such as a chosen field of study, participation in sports or clubs,…
Approves a foundation's statewide college-scholarship procedures under 4945(g)
A private foundation runs a named scholarship program that awards grants to high school seniors across one state who are heading to a two- or four-year college. It asked the IRS to approve its award p…
Approves a private foundation's scholarship grant procedures for students in two countries
A private foundation asked the IRS to approve, in advance, the procedures it uses to award scholarships to students in two countries. Private foundations normally owe an excise tax on grants to indivi…
IRS approves a private foundation's training-center set-aside
A private foundation that helps economically disadvantaged youth planned to build a training center while continuing its scholarship program. The project required land acquisition, construction, local…
IRS approves a private foundation's scholarship procedures
A private operating foundation proposed one-time scholarships for undergraduate and graduate students who belonged to the organization. It publicized the program, excluded insiders and prior recipient…
IRS approves a scientific-research grant set-aside
A private foundation sought to set aside funds for a new scientific research grant program focused on cancer, aging, and regeneration. The program required time to publicize the opportunity, evaluate …
IRS approves need-based scholarship procedures
A private foundation proposed scholarships for students attending primary, secondary, undergraduate, and graduate schools. It would publicize the program locally and select recipients based on financi…
Foundation's first-generation scholarship procedures approved
A private foundation proposed renewable scholarships for financially needy students who would be among the first in their immediate families to pursue post-secondary education. Applicants also had to …
Foundation's international scholarships and professional grants approved
A private foundation proposed two programs for adults in the United States and abroad, with preferences tied to a specified state, counties, and national descent. Its scholarship program would support…
Foundation's four-year college scholarship procedures approved
A private foundation proposed scholarships for graduating high school seniors from two states who planned to attend accredited four-year colleges or universities in one of three states. Applicants had…
Employer-related scholarships for employees' children approved
A private foundation proposed renewable scholarships for dependent children of full-time employees of a beer distributor. Eligible students had to meet age and parental-service requirements, pursue fu…
Foundation's unconventional workshop grant procedures approved
A private foundation proposed educational grants enabling recipients to attend short, unconventional workshops offered by third parties. The workshops would develop professional, literary, musical, ar…
Foundation's scholarships and tobacco-research grants approved
A private foundation proposed both academic scholarships and grants for independent research on smoking cessation, tobacco harm reduction, and alternatives for tobacco farmers. Scholarship recipients …
Leadership-development grant procedures approved
A private foundation proposed educational grants for activists, community leaders, charity workers, students, scholars, and others working toward charitable social change. Grants could fund education,…
Employer-related scholarship procedures approved
A private foundation proposed scholarships for children of employees of five public-service and other employers. Recipients would be selected on merit through applications, references, and interviews,…
Art study-abroad grant procedures approved
A private foundation proposed one-time grants for undergraduate and graduate art students participating in a university study-abroad program. The grants would cover program fees, group travel, accommo…
Art study-abroad grant procedures approved
A private foundation proposed one-time grants for undergraduate and graduate art students participating in a university study-abroad program. The grants would cover program fees, group travel, accommo…
Visual-artist grant procedures receive advance approval
A private foundation proposed annual grants for emerging and mid-career visual artists in a particular state to create new work and improve their skills. Two panels of visual-arts professionals would …
Scientific-research travel and collaboration grant procedures approved
A private foundation sought advance approval for grants supporting individuals involved in a scientific research initiative. The grants would fund study, research, writing, lecturing, publication, and…
Research and travel grant procedures approved
A private foundation proposed six grant programs supporting research on a historical periodical press, scholarly databases and resources, dissertation work, research leave, and conference travel. Appl…
School leadership capacity grant program approved
A private foundation proposed a grant program to strengthen the leadership and long-term sustainability of religious day schools. Selected schools would receive coaching, seminars, webinars, consultin…
Below-market educational loan procedures approved
A private foundation proposed a program making one-year, below-market loans for postsecondary study at colleges, universities, nursing programs, commercial-training programs, and trade or vocational s…
Independent-school scholarship procedures approved
A private foundation proposed scholarships for students in prekindergarten through grade 12 who attended or had been accepted by independent schools in four counties. Applicants would be evaluated on …
Faculty professional-development grant procedures approved
A private foundation proposed grants to improve the teaching skills and talents of faculty members at independent schools in four counties. Applicants would submit project descriptions, goals, budgets…
Aspiring-teacher scholarship procedures approved
A private foundation proposed renewable scholarships and professional support for university students preparing to become teachers in economically disadvantaged public schools or high-need subject are…
Employer-related scholarships for employees' children approved
A private foundation proposed one-year scholarships for children of current employees of a company and its domestic subsidiaries. An independent committee with no current or former employees of the fo…
Mathematics grant procedures approved
A private foundation proposed three programs supporting undergraduate mathematics education, enrichment, and related teaching or research activities. One program would provide multiyear summer tuition…
Scientific conference travel grants approved
A private foundation proposed grants for graduate students and postdoctoral researchers to travel to scientific conferences and similar educational events concerning the study of intelligence. Grants …
Need-based community scholarships approved
A private foundation proposed scholarships for financially needy students graduating from specified high schools in several communities. High schools would screen applications and forward up to three …
Employer-related scholarships approved
A private foundation proposed scholarships for children and grandchildren of employees of a corporation and its affiliates. Eligible applicants would be recent high school graduates or current undergr…
Healthcare education scholarships approved
A private foundation proposed renewable scholarships for students pursuing post-secondary healthcare education in the area served by a hospital. Awards could continue for up to four years while recipi…
Charity leader sabbatical grants approved
A private foundation proposed sabbatical grants for individual leaders of charities to pursue personal and professional growth through conferences, courses, travel, extended learning, and rejuvenation…
Employer-related scholarship procedures received advance approval
A private foundation proposed scholarships for dependent children of an employer's full-time employees. An independent committee would select recipients using academic performance, activities, goals, …
Technical education scholarship procedures received advance approval
A private foundation proposed scholarships for low-income high school graduates pursuing two-year technical degrees or certifications at local community colleges. Applicants had to meet citizenship or…
Foundation's music education grant procedures approved
A private foundation proposed grants for children ages 4 through 17 to study music, take theory classes or lessons, and obtain appropriate instruments. Applicants would submit financial and educationa…
Foundation's four-year scholarships for local students approved
A private foundation proposed renewable scholarships for financially needy high school seniors from three counties who planned to attend public universities in their state. Eligible applicants also ha…
Foundation's grants for emerging women and LGBTQ filmmakers approved
A private foundation proposed one-year production grants for emerging filmmakers in a metropolitan area who identify as female or LGBTQ and are making films or videos about art or artists. Applicants …
Scholarships rewarding local historical-site knowledge approved
A private foundation proposed one-time scholarships for graduates of local high schools who showed interest in and knowledge of a historic site. Applicants needed a good academic record, a passion for…
Education grants for people rebuilding after addiction, homelessness, or incarceration approved
A private foundation proposed educational grants for people recovering from substance abuse or addiction, experiencing homelessness, returning to society after incarceration, or otherwise facing finan…
Scholarship grant procedures received advance approval
A nonexempt charitable trust operated a scholarship program for local high school students. A committee of school officials selected recipients using equally weighted scholarship, ability, need, and o…
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.