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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Employer-related scholarship and educational grant procedures approved
A private foundation proposed an employer-related program offering both scholarships for accredited education and educational grants for summer programs, evening classes, and talent development to qua…
Student research grant procedures received advance approval
A private foundation proposed educational research grants for college and university students studying a redacted specialty and related scientific contexts. Applicants needed faculty support, institut…
Private capital research grant procedures received advance approval
A private foundation proposed grants for independent academic research on the economic impact of the private capital industry using secure, centralized databases. Academic applicants would submit rese…
Entrepreneurship research grant procedures received advance approval
A private foundation proposed grants for research designed to produce practical insights for entrepreneurs, entrepreneurship programs, policy designers, ecosystem leaders, and researchers. A public ca…
Foundation could pay its founder's entity for charitable services
A private foundation proposed paying an entity owned by its founder for professional grant-making, program, charitable consulting, and investment services. Because the founder was a substantial contri…
Founder-owned entity could receive fees for foundation services
A private foundation proposed paying an entity owned by its founder for professional grant-making, program, charitable consulting, and investment services. Because the founder was a substantial contri…
IRS approved a private foundation's scholarship procedures
A private foundation proposed scholarships for undergraduate and graduate students studying in two specified fields at accredited universities. An independent scholarship administrator would handle ap…
IRS approved four-year scholarships for graduating seniors
A private foundation proposed four-year undergraduate scholarships for graduating seniors from qualifying high schools in two regions. School representatives would nominate candidates, and a scholarsh…
IRS approved annual nursing scholarships based on merit and need
A private foundation proposed annual scholarships for full-time students in specified nursing programs at a college. Applicants needed a minimum 3.5 grade point average and demonstrated financial need…
IRS approved community and employer-related scholarships
A private foundation proposed one scholarship program for graduates of a local school system and another for children of employees of two companies. Separate advisory committees would evaluate applica…
IRS approved scholarships for math, science, and education students
A private foundation proposed renewable scholarships for students from a specified area who would attend college in a specified state and pursue mathematics, science, or education degrees. Applicants …
Employer-related scholarship procedures received advance approval
A private foundation proposed scholarships for lineal descendants of employees of affiliated companies. An independent community committee would select recipients using academic, extracurricular, and …
Foundation's two college scholarship programs received advance approval
A private foundation requested advance approval for two need-based scholarship programs designed to help students complete college with little or no debt. One program served promising students statewi…
Open-access biomedical research prizes received advance approval
A private foundation proposed grants for finalists in an international biomedical design competition operated with a foreign organization. Senior staff and an expert biotechnology panel would screen w…
Modified employee-child scholarship program received approval
A private foundation modified an existing scholarship program for children of employees of a related corporation in the United States and a foreign country. An independent tax-exempt administrator and…
National finalist scholarship for employees' children received approval
A private foundation proposed four-year college scholarships for up to two children of employees of a related company. Recipients first had to become finalists in an independent nonprofit organization…
Scholarship for economically challenged graduates received approval
A private foundation proposed a scholarship for graduates of a specified school program who had overcome economic challenges and been accepted by a highly ranked out-of-state university. The award cou…
Employee-children scholarship procedures received approval
A private foundation proposed one-year, nonrenewable scholarships for children of employees of a related private company. An independent third-party administrator would publicize and administer the pr…
Regional artist grant procedures received approval
A private foundation proposed grants for adult artists living and working in a specified city region. The program supported projects in media, performing, literary, and visual arts and evaluated artis…
Grassroots social-change grant procedures received approval
A private foundation proposed grants to people from low-income communities for grassroots projects addressing housing, transportation, cooperative businesses, youth leadership, community organizing, a…
Agriculture scholarship procedures received approval
A private foundation proposed nonrenewable scholarships for students pursuing post-secondary agriculture-related degree programs in the United States and another country. An independent committee of a…
Fellowship grant procedures for young innovators approved
A private foundation proposed a fellowship program for young innovators and leaders whose projects would improve life in their state. It expected to award five stipends per year during a trial period,…
IRS approves a private foundation's scholarship-grant procedures under § 4945(g)
A private foundation asked the IRS to approve, in advance, the procedures it uses to award college scholarships. Private foundations normally owe an excise tax on grants to individuals for study, but …
Music scholarship and educational grant procedures approved
A private foundation requested advance approval for a grant program supporting young classical musicians. The program would make merit-based awards for music education, lessons, sheet music, or instru…
Employer-related scholarship procedures approved
A private foundation requested advance approval for renewable scholarships benefiting eligible children of a company’s nonunion, full-time employees and employees of its affiliates. Awards could suppo…
Student-loan payoff grant procedures received advance approval
A private foundation proposed one-time grants to help selected college seniors pay outstanding student loans. Eligibility was limited to current recipients of another scholarship, and an independent c…
Employer-related scholarship procedures received advance approval
A private foundation proposed scholarships for children, dependents, and grandchildren of employees of a related employer. An independent committee would select recipients using academic performance, …
Refugee and immigrant scholarship procedures received approval
A private foundation proposed nonrenewable scholarships for current or former refugee and immigrant clients of a charitable organization and members of their families. Applicants had to fall within a …
International student grant procedures received advance approval
A private foundation proposed scholarships for highly capable students at an institution in another country to pursue post-secondary education or training in the United States or, in some cases, their…
Scholarship procedures for association members’ descendants approved
A private foundation proposed scholarships for children and grandchildren of association members who had maintained membership for at least three years and were current on dues. Applicants had to be a…
Museum construction set-aside received advance approval
A private foundation planned to build and operate a museum devoted to a continent’s culture and history. It requested approval to set aside funds because the multi-year design and construction work de…
Learning-disability scholarship procedures received advance approval
A private foundation proposed scholarships for students with documented learning disabilities to attend private high schools in a metropolitan area. Awards would cover tuition, books, school fees, and…
IRS pre-approves a community foundation's scholarship-grant procedures under Section 4945(g)
A private foundation asked the IRS to approve, in advance, the way it will run a scholarship program so that the grants do not count as "taxable expenditures" under Section 4945. Private foundations o…
Foundation's educational grant procedures for charter-school graduates approved under 4945(g)(3)
A private foundation received advance IRS approval of its educational grant procedures under Code Section 4945(g)(3), a companion to the scholarship rule that keeps a foundation's grants to individual…
Foundation's memorial scholarship procedures for relatives of insurance agents approved under 4945(g)
A private foundation received advance IRS approval of its scholarship grant procedures under Code Section 4945(g), which spares the foundation the Section 4945 excise tax that otherwise applies to gra…
Foundation's robotics/STEM scholarship procedures approved under 4945(g)
A private foundation got advance IRS approval of the procedures it uses to award scholarships, which keeps the grants from being "taxable expenditures" that would trigger the Section 4945 excise tax. …
Foundation's primary-care provider scholarship procedures approved under 4945(g)
A private foundation received advance IRS approval of its scholarship grant procedures under Code Section 4945(g), which lets a foundation avoid the Section 4945 excise tax on grants to individuals wh…
Foundation's scholarship procedures for students of a particular descent approved under 4945(g)
A private foundation asked the IRS to approve, in advance, the procedures it uses to award scholarships, and the IRS said yes. Private foundations owe an excise tax under Code Section 4945 on "taxable…
Employer-related scholarship procedures approved under § 4945(g)(1)
A private foundation asked the IRS to approve in advance the way it runs an employer-related scholarship program, which awards college scholarships to the dependent children of employees at several af…
Charitable trust contributions remained incomplete gifts and avoided split-interest trust rules
A settlor created an irrevocable trust for individuals and a foundation while retaining consent and limited appointment powers. The IRS ruled that the initial contribution was an incomplete gift and t…
Gift of nonvoting LLC interests to charitable trust avoided self-dealing
A trust creator planned to give a charitable lead annuity trust nonvoting interests in an LLC whose only assets were promissory notes owed by trusts for descendants. Those note obligors were disqualif…
Renewable college scholarship procedures approved
A private operating foundation sought approval for a renewable college scholarship program serving high school students in its local area. Applicants had to rank in the top ten percent of their class,…
Employer-related college scholarship procedures approved
A private foundation proposed nonrenewable college scholarships for children of employees of a company and its subsidiaries. An outside organization would administer the program and independently sele…
Private foundation may set aside funds for facility renovations
A private foundation planned a multiyear renovation of its operating facility and requested approval to set aside funds rather than pay them immediately. The IRS approved the set-aside under section 4…
Private foundation's scholarship procedures are approved
A private foundation requested advance approval for a college scholarship program. The IRS approved the procedures under section 4945(g)(1), so grants made under them would not be taxable expenditures…
Scholarship grant procedures approved for a private foundation
A private foundation asked the IRS to approve its procedures for scholarships to high school seniors who have been accepted by qualifying U.S. universities but lack the resources to attend. A selectio…
Private foundation's set-aside to build a cultural and arts facility is approved as a qualifying distribution
A private foundation must pay out a minimum amount for charitable purposes each year, but it can instead "set aside" funds for a specific long-term project and still count them as a qualifying distrib…
IRS approves a private foundation's scholarship grant procedures in advance
When a private foundation gives grants to individuals for study, those payments are normally "taxable expenditures" that trigger excise taxes, unless the IRS approves the foundation's award procedures…
Private foundation's set-aside to convert a building into a museum is approved as a qualifying distribution
A private foundation normally has to pay out a minimum amount each year for charitable purposes, but instead of spending immediately it can "set aside" money for a specific long-term project and still…
Employer-related scholarship procedures approved for a private foundation
A private foundation asked the IRS to approve an employer-related scholarship program for employees' dependent children. An independent third-party administrator will publicize the program, process ap…
IRS pre-approves a foundation's internship and research grant procedures
A private foundation asked the IRS to approve, in advance, the procedures it uses to award educational grants under Internal Revenue Code section 4945(g)(3). Private foundations normally owe an excise…
IRS pre-approves a foundation's medical-school pipeline scholarship program
A private foundation asked the IRS to approve, in advance, the procedures for a scholarship program it runs to fund the education of certain qualifying students. Private foundations normally owe an ex…
Private foundation gets 60 extra days to make a late conduit-foundation election so its donors keep the 50% deduction limit
A private foundation that regrants money to other charities wanted "conduit foundation" treatment, which lets its individual donors deduct contributions at the higher 50 percent of income limit (like …
Foundation's religion-journalism grant is a qualifying distribution, not a taxable expenditure
A private foundation proposed funding a Type I supporting organization's global religion-journalism project. The project would use nonprofit and for-profit collaborators to produce objective, educatio…
IRS approves a private foundation's journalism fellowship procedures
A private foundation proposed a 12-month fellowship that would provide salary, benefits, training, and newsroom placements to early-career journalists. Applicants would be evaluated through published …
IRS approves a private foundation's pharmacy innovation grant procedures
A private foundation proposed competitive grants for licensed pharmacists in a specified state or researchers working with innovative pharmacy practice by pharmacists in that state. Applicants had to …
IRS approves a private foundation's health-care scholarship grant procedures
A private foundation that funds health-care education asked the IRS to approve in advance the way it selects and awards scholarships. Under Code Section 4945, grants a private foundation makes to indi…
IRS approves a foundation's scholarship procedures for charter-school graduates
A private foundation asked the IRS to approve in advance how it awards a scholarship program aimed at charter high school seniors. Private foundations that give grants to individuals for study can fac…
Court-approved sale of inherited shares can avoid indirect self-dealing
A private foundation expected to receive shares of a family corporation from its founder's trust. Litigation required the trust to sell those shares to the corporation, which was a disqualified person…
Foundation receives rules for inherited business interests, apartment rent, and mortgage debt
A private foundation is the remainder beneficiary of a trust that will distribute corporate and limited liability company interests after the death of the current beneficiary. The assets include an in…
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.