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 procedures are approved
A private foundation requested advance approval for scholarships offered to children and other relatives of an employer's employees. An independent organization would select recipients through highly …
Descendant scholarship procedures are approved
A private foundation proposed scholarships for former employees of a company that had closed more than 50 years earlier, as well as their spouses, parents, and descendants. Awards would be based on ac…
Revised statewide scholarship procedures are approved
A private foundation that already had approval for a scholarship program proposed three changes. Most applicants would need to be credit union members or have a parent who was a member, scholarships w…
Private foundation may set aside funds to build a boarding school
A private foundation proposed to build a tuition-free boarding school for high-achieving public school students who met its scholarship eligibility standard. The project required acquiring a site, com…
IRS approves a private foundation's scholarship procedures for a global math and science video competition
A private foundation runs an annual global competition for high school students, asking them to make a short video that teaches a difficult math or science concept in an engaging way. It asked the IRS…
IRS approves a private foundation's merit-based scholarship procedures for a university program
A private foundation set up a merit-based scholarship to help students earn an undergraduate or graduate degree at a particular university. It asked the IRS to approve, in advance, how it selects and …
IRS pre-approves a private foundation's scholarship program, so the grants are not taxable expenditures
Private foundations normally owe a penalty excise tax when they hand money to individuals for study or similar purposes, unless the IRS approves the grant-making procedures in advance. Here a private …
Private foundation may set aside funds to recruit and train a charter school leader
A private foundation that funds education initiatives (pre-K through 12 schooling, charter school formation, teacher and leadership development, and after-school programs) asked the IRS to approve a "…
Approves a private foundation's scholarship procedures for students in a specialty field
A private foundation asked the IRS to approve its procedures for awarding nonrenewable scholarships to students studying in a specialty field at accredited U.S. post-secondary institutions. Applicants…
Approves renewable need-based scholarships for students from a financially depressed community
A private foundation asked the IRS to approve a scholarship program for high-school graduates who live in a financially depressed community and previously attended specified primary or middle schools.…
Approves cultural project and travel grants to individuals
A private foundation proposed two nonrenewable grant programs to promote understanding and preservation of a particular culture and its history. One program funds research, scholarship, artwork, perfo…
Advance approval of a private foundation's scholarship procedures for economically disadvantaged foreign students under section 4945(g)(1)
A private foundation asked the IRS to approve, in advance, the procedures for a scholarship program funding the education of economically disadvantaged students in foreign countries, aiming to give th…
Advance approval of a private foundation's procedures for postdoctoral science research fellowships under section 4945(g)(3)
A private foundation asked the IRS to approve, in advance, the procedures for a program that funds three-year fellowships for postdoctoral scientists working in physical and life sciences, technology,…
Advance approval of a private foundation's procedures for two artist grant programs under section 4945(g)(3)
A private foundation that funds the arts asked the IRS to approve, in advance, the procedures for two educational grant programs supporting individual artists. This advance approval matters because gr…
Advance approval of an employer-related scholarship program
A private foundation, funded by the founder of a for-profit corporation and his wife, asked the IRS to approve in advance the way it will run an employer-related scholarship program. This approval mat…
Foundation's health-care scholarship procedures approved under 4945(g)(1)
A private foundation runs a scholarship program for local residents pursuing health-care degrees or certifications at nearby schools, and asked the IRS to approve how it selects recipients. Private fo…
Foundation's band-scholarship procedures approved under 4945(g)(1)
A private foundation runs a scholarship for graduating senior band members at a particular school and asked the IRS to approve how it picks winners. Private foundations owe an excise tax on grants to …
Global-citizenship foundation's scholarship and travel grant procedures approved under 4945(g)(3)
A private foundation runs a global-citizenship fellowship and asked the IRS to bless the way it hands out grants to the individual fellows. Private foundations normally owe an excise tax when they pay…
201835014: Denies litigation-related set-asides because no court order barred distributions
A private foundation sought advance approval to set aside specified amounts for two fiscal years while it litigated with the charitable beneficiary named in the testator's will. The foundation had sto…
201835013: Approves a set-aside for botanical garden construction and improvements
A private foundation operating a botanical garden sought to set aside funds for two long-term construction projects. One project would build a visitor center with meeting, greenhouse, retail, café, ex…
Approves scholarship procedures for students from three high schools
A private foundation requested advance approval under section 4945(g) for a scholarship program serving graduating seniors from three high schools. It expected to select one student from each school a…
Approves need-based scholarship procedures for graduates of one school
A private foundation requested advance approval under section 4945(g) for scholarships to financially needy graduates of a particular school who enrolled at accredited educational institutions. The an…
Approves undergraduate and trade scholarship procedures
A private foundation requested advance approval under section 4945(g) for scholarships to students pursuing undergraduate degrees or trade and certificate programs. The board would set the annual numb…
Approves employer scholarship procedures
A private foundation requested advance approval for scholarships to employees of a company and their dependent children. It initially planned four awards for employees and two awards for dependents, w…
Approves ancestry-based scholarship procedures
A nonexempt charitable trust treated as a private foundation requested advance approval for a scholarship program serving students with one of two specified ancestries. Awards could cover tuition, fee…
Approves research grants for medical trainees
A private foundation requested advance approval for grants to promising physician residents and fellows at tax-exempt hospitals in specified cities. The grants would support research and training in a…
Approves scholarship and study-abroad grant procedures
A private foundation requested advance approval for both scholarships and educational fellowships. Scholarships would support study at accredited colleges, universities, vocational schools, and trade …
Approves arts-campus construction set-aside
A private foundation requested approval to set aside a redacted amount for an arts campus centered on rehabilitating a vacant historic church. The set-aside would fund infrastructure and tenant improv…
Study-abroad fellowship procedures approved
A private foundation proposed a two-week study-abroad fellowship program for undergraduate and graduate students from one country. The program would develop participants' leadership and entrepreneuria…
Innovation grant procedures approved under § 4945(g)(3)
A private foundation asked the IRS to approve in advance the procedures for an educational grant program it planned to run. The program would make small grants to individuals (open to applicants 18 or…
A QTIP trust that will fund a foundation is not yet subject to the private-foundation excise taxes
A married person set up a trust that, at death, became irrevocable and was elected to be qualified terminable interest property (QTIP) for estate tax purposes. The surviving spouse receives all the tr…
A private foundation gets extra time to make a missed corpus-distribution election
A private foundation received large stock contributions from substantial donors and made grants, but it did not distribute a full 100 percent of those contributions in the same year. To help its donor…
Scholarship procedures for underprivileged students approved
A private foundation proposed scholarships to help underprivileged students complete undergraduate or graduate degrees. Applicants would provide academic records and essays, and a selection committee …
High-school entrepreneurship grants approved
A private foundation proposed grants to startup businesses developed, managed, and majority-owned by students at two high schools. Applicants would submit business plans and supporting materials, and …
Graduation awards are charitable distributions, not taxable expenditures
A private operating foundation provided scholarships and a required financial education program to high-achieving students with financial need from rural counties. Students learned investment skills b…
Employer-related scholarship procedures receive advance approval
A private foundation proposed a nonrenewable scholarship program for children and dependents of employees of a company and its subsidiaries. An independent committee would select recipients using fina…
Conservation land excluded from minimum investment return
A private operating foundation maintained undeveloped desert land adjoining its historic developed property. The land served as a security buffer for charitable and educational events, supported garde…
Scholarship and educational grant procedures are approved
A private foundation requested advance approval for two programs serving students with financial need and academic promise. Its scholarship program would support private high school, college, and grad…
Franchise-employee scholarship procedures are approved
A private foundation proposed scholarships for employees of independently owned franchises pursuing undergraduate or vocational education. An unrelated Section 501(c)(3) organization would administer …
Scholarships for an employer's employees' children are approved
A private foundation proposed scholarships for dependent children of an employer's full-time employees. An independent organization would administer the applications, select recipients based on financ…
Foundation's summer-camp grant procedures receive advance approval
A private foundation proposed educational grants that would help children attend overnight summer camps promoting their religious identity, traditions, history, and culture. Eligible recipients genera…
Outdoor art installation grant procedures receive advance approval
A private foundation proposed a grant program for individuals creating durable and safe outdoor art installations, such as sculptures and murals. Applicants would submit an artwork statement, images, …
Scholarship and support grants for disadvantaged women receive approval
A private foundation proposed grants to help academically successful but financially disadvantaged women from a redacted country attend educational institutions in the United States. The program would…
Foundation conversion allowed beneficiary payments and split-year reporting
A non-functionally integrated Type III supporting organization planned to become a private foundation and combine two asset funds after a court-approved trust modification. Under a settlement, smaller…
Artist alumni scholarship and project grants receive approval
A private foundation proposed four grant programs for alumni of an arts organization who had completed high school and participated in the organization for at least two years. One program would provid…
Historic preservation matching-grant set-aside receives approval
A private foundation proposed setting aside a matching grant equal to one-third of the estimated cost of restoring the exterior of a historically and culturally significant building listed on the Nati…
Wildlife habitat property set-aside receives approval
A private foundation devoted to wildlife, nature conservation, and balanced ecology wanted to acquire property near important waterways to protect habitat from commercial development. It had tried uns…
Historic theater matching-grant set-aside receives approval
A private foundation proposed a matching grant equal to about one-third of the estimated cost of restoring a historic theater listed on the National Register of Historic Places. The recipient public c…
Private foundation scholarship procedures receive advance approval
A private foundation proposed a scholarship program for qualifying students pursuing post-high-school education. Awards could cover tuition, required fees, books, supplies, equipment, and room and boa…
Architecture travel-research grant procedures receive approval
A private foundation proposed an annual, nonrenewable travel and research grant for graduate students in architecture, historic preservation, and urban design. Applicants had to attend one of a specif…
Employer-related scholarship procedures receive approval
A private foundation proposed college scholarships for children and certain other relatives of employees of a company and its subsidiaries. An outside organization would select recipients through a hi…
High school scholarship procedures receive advance approval
A private foundation proposed annual scholarships for high school students attending public or private schools in a specified county. Awards would pay tuition and fees, and the program would be public…
Hospice house set-aside receives approval
A Type III non-functionally integrated supporting organization requested approval to set aside funds for its supported organization. The project would construct a hospice house benefiting hospice pati…
Historic building restoration set-aside receives approval
A private foundation proposed a matching grant to a public charity restoring a historically significant building for use as a history center. The grant agreement required the charity to raise matching…
Leadership capacity-building grant procedures receive approval
A private foundation proposed a capacity-building program for leadership teams from selected charitable organizations in a faith community. The program included board and chair assessments, seminars, …
Charitable loan program qualifies for two private-foundation exceptions
A private operating foundation proposed loans to nonprofit and for-profit service providers helping underserved children and families, as well as intermediaries experienced in charitable lending. The …
Policy research grant procedures receive advance approval
A private foundation proposed grants for scientists, authors, and researchers to develop original projects addressing domestic and international policy, economic, and social issues. Applicants would s…
Public arts grant procedures received advance approval
A private foundation proposed small grants for artists and performers to create public-minded fine and performing arts projects, initially in two counties of a metropolitan area. Applicants would subm…
Computer science scholarship procedures received approval
A private foundation proposed scholarships for underprivileged students enrolled full-time in a computer science bachelor's degree program at a specified school. Applicants had to meet a minimum high-…
Foundation's social-impact grant procedures were approved
A private foundation proposed annual grants to individuals or teams pursuing projects involving civil rights, humanitarian concerns, environmental protection, and related social issues. Staff, outside…
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.