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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Approves grants connecting expatriate youth with their country
A private foundation proposed an educational grant program for alumni seeking to strengthen ties between a country and young people from that country who lived abroad. Applicants would propose project…
Approves graduate STEM scholarship for young women
A private foundation proposed a merit scholarship for a female high school junior or senior from either of two states who intended to pursue graduate study in science, technology, engineering, or math…
Approves scholarship contest and spiritual research grants
A private foundation proposed two individual grant programs. One was an essay or video contest for high school seniors and college undergraduates, with scholarships paid through accredited educational…
Approves scholarships for students connected to a community
A private foundation proposed scholarships for high school and college-age students who had a connection to a specified community. Applicants would submit an essay and transcripts, and trustees would …
Approves cross-disciplinary research and leadership grants
A private foundation proposed grants for recent PhD recipients in science, technology, engineering, and mathematics. Recipients would conduct postdoctoral research outside their planned field and comp…
Approves photography grants for social-change projects
A private foundation proposed grants for working photographers and visual storytellers whose projects could promote positive social change. An open call and a nominating committee would identify candi…
Employer-related scholarship procedures receive advance approval
A private foundation proposed scholarships for children and other relatives of employees of a company and its subsidiaries. An independent organization and its selection committees would choose recipi…
Scholarship procedures for graduates of two schools receive approval
A private foundation proposed a scholarship for students who graduated from two specified schools and met stated grade and course-completion requirements. Every qualifying eighth grader at one school …
IRS approves a private foundation's grants for developing new theatrical works
A private foundation asked the IRS to approve its procedures for grants that help individuals study the arts and develop new theatrical works. Applicants would submit scripts and other production mate…
IRS approves a private foundation's nursing scholarships
A private foundation asked the IRS to approve scholarships for financially needy students entering their junior or senior year in a nursing program. Recipients would be selected based on financial nee…
IRS approves renewable college scholarships for graduating seniors
A private foundation proposed scholarships for graduating seniors from a specified school who had been admitted to college, generally targeting students with at least a 3.0 GPA. Selection would consid…
IRS approves trade-school scholarships for low-income high school seniors
A private foundation proposed scholarships for low-income graduating seniors who wanted trade training rather than a traditional college program. Applicants would document financial need, explain thei…
Employer-related scholarship procedures are approved
A private foundation proposed one nonrenewable scholarship each year for a child of a company employee with at least three years of service. Applicants had to be college sophomores, juniors, or senior…
Botanical fellowship and internship grant procedures are approved
A private foundation proposed two educational grant programs in botanical science and art, plant biology, horticulture, gardens, landscape design, plant uses, and conservation. One would make generall…
Medical travel and international research grant procedures are approved
A private foundation proposed two educational grant programs in a redacted medical specialty. The first would help outstanding residents travel to a professional organization's annual meeting after su…
Foreign foundation receives late disregarded-entity election for investment vehicle
A foreign tax-exempt private foundation held its U.S. investment portfolio through a single-owner foreign investment vehicle whose custodians had withheld U.S. tax from dividends. The foundation had r…
Scholarship program for career changes after serious illness is approved
A private foundation proposed full scholarships for people who need a new career because they or a dependent have a life-changing illness or similar condition. Eligible study could include an advanced…
Ministry scholarship procedures approved
A private foundation proposed one-time scholarships for full-time students pursuing advanced religious studies at accredited theological seminaries, colleges, or universities. Applicants had to meet a…
Nursing scholarship procedures approved
A private foundation proposed scholarships for state residents pursuing full-time nursing degrees at colleges or universities in the state. Applicants had to be entering their sophomore, junior, or se…
Seminary scholarship procedures receive advance approval
A private foundation proposed scholarships for students pursuing Christian seminary studies and future missionary or ministry work. Applicants had to show academic ability, character, motivation, fina…
Private foundation's energy-industry scholarship procedures are approved
A private foundation sought advance approval for a scholarship program serving high school graduates in areas where an affiliated energy company operates. Applicants would pursue specified science, ma…
Private foundation's need-based scholarship procedures are approved
A private foundation proposed scholarships for students attending schools in specified regions or otherwise demonstrating financial need. A selection committee would consider academic performance, rec…
Internship-completion educational grants receive advance approval
A private foundation proposed grants to encourage high school seniors to complete a citywide career-training and internship program. Participants would receive three equal installments as they complet…
Creative-residency fellowship procedures receive advance approval
A private foundation proposed nonrenewable fellowships supporting accomplished members of a global cultural and religious community during creative residencies in a city. An advisory committee would i…
A foundation may indemnify trustees for accelerated trust distributions
A private foundation was the sole remaining beneficiary of an irrevocable trust and wanted the trustees to distribute trust assets before all potential liabilities were resolved. The foundation propos…
A foundation's four scholarship programs received advance approval
A private foundation requested advance approval for procedures governing four scholarship programs designed to expand access to higher education. The programs used academic ability, financial need, ch…
College scholarship procedures receive advance approval
A private foundation proposed scholarships for undergraduate and postgraduate students who had demonstrated academic success and needed financial assistance. Applicants would submit academic, personal…
Renewable college scholarship procedures receive advance approval
A private foundation proposed renewable scholarships for high-achieving high school seniors, including homeschooled students, who needed financial assistance and had been accepted by four-year college…
Foster-care student scholarship programs receive advance approval
A private foundation proposed two scholarship programs for high school graduates who were in foster care, had previously experienced foster care, or faced similar disadvantages. One program would serv…
STEM scholarship procedures receive advance approval
A private foundation proposed annual scholarships for underprivileged local high school graduates beginning four-year undergraduate programs in science, technology, engineering, or mathematics. Applic…
Environmental leadership scholarship procedures receive advance approval
A private foundation proposed a one-time annual scholarship for a high school junior or senior who showed leadership and initiative through a conservation, preservation, restoration, or environmental …
Set-aside approved for construction of a specific exhibit
A private foundation requested approval to set aside a redacted amount for a specific exhibit planned by another organization. The exhibit was part of a larger capital campaign, and the long planning …
Professional-development grant procedures received advance approval
A private foundation proposed grants for professional-development opportunities benefiting people who work at its grantee organizations. Applicants could seek funding for conferences, training, semina…
Medical scholarship procedures received advance approval
A private foundation proposed scholarships for students pursuing premedical or medical studies at accredited colleges and universities and planning medical careers. Applicants would be evaluated on ac…
Foreign foundation's indirect investment avoided excess business holdings
A foreign private foundation proposed investing in a foreign passive holding company that could own all of an operating business. The foundation would own the holding company's nonvoting shares and vo…
Transitional scholarship procedures received advance approval
A private foundation designed a scholarship program with partner colleges for people who might not normally receive transitional academic scholarships. Eligible applicants included adults with depende…
College-partnership scholarship procedures received advance approval
A private foundation proposed multi-year scholarships for promising students at collaborating four-year colleges and universities who had strong academic records, significant unmet financial need, or …
Set-aside approved for a matching grant to restore a historic building
A private foundation requested approval to set aside a grant for a public charity restoring the steeple and tower of a historic building. The grant would cover about one-third of the project cost and …
Scholarship and internship grant procedures approved
A private foundation proposed three scholarship programs and a supplemental internship grant program. The scholarships would support low-income private-school students, college students with financial…
Youth leadership and community-project grants approved
A private foundation proposed a leadership program for selected public high school juniors, their educators, and a smaller group of students and an educator from an overseas partner. The program would…
Private foundation scholarship procedures were approved
A private foundation proposed scholarships for high school seniors attending four-year colleges or community colleges, initially within a specified geographic area. Recipients would be selected based …
Multiyear college scholarship procedures were approved
A private foundation proposed scholarships for graduating high school seniors entering college. Applicants needed at least a 3.0 GPA and would submit a resume and essay, with finalists selected throug…
Trust conversion is nontaxable and not self-dealing but gives no new deduction
A split-interest trust proposed adding a substitution power that would convert it from a nongrantor trust to a grantor trust. The power would be held in a nonfiduciary capacity by the grantor's siblin…
Trust conversion is nontaxable and not self-dealing but gives no new deduction
A split-interest trust proposed adding a substitution power that would convert it from a nongrantor trust to a grantor trust. The power would be held in a nonfiduciary capacity by the grantor's siblin…
Trust conversion is nontaxable and not self-dealing but gives no new deduction
A split-interest trust proposed adding a substitution power that would convert it from a nongrantor trust to a grantor trust. The power would be held in a nonfiduciary capacity by the grantor's siblin…
Employer-related scholarship procedures approved
A private foundation asked the IRS to approve procedures for one-time scholarships for qualifying children of active, retired, and deceased employees of a company. An independent public charity would …
Local academic scholarship procedures approved
A private foundation proposed up to five annual scholarships for high school seniors in a particular geographic area who planned to attend nonprofit colleges in the United States. The foundation would…
Historic-home matching grant qualifies for a set-aside
A private foundation proposed a matching grant to a public charity restoring the historic home of a former United States president. Payment depended on the charity raising matching funds, securing app…
Broad scholarship procedures approved
A private foundation proposed scholarships for students ranging from primary and secondary school through graduate and professional education. It would publicize the program broadly, apply objective c…
Foundation may set aside funds for a performing arts venue
A private operating foundation was formed with a corporate donation to operate and maintain a performing arts theater and related space within a larger development. Construction was expected to take f…
Foundation may set aside funds for a future academic symposium
A private foundation planned a second academic symposium for promising young scholars from around the world. It proposed reserving equal amounts in two different years and spending all of the funds on…
Foundation's international student scholarship procedures are approved
A private foundation proposed scholarships primarily for financially needy students from impoverished countries who would study in the United States, while also allowing U.S. students to apply. Awards…
Foundation's renewable college scholarship procedures are approved
A private foundation proposed renewable scholarships for residents of a state who were enrolled or planning to enroll at a qualifying college or university. Applicants would submit an essay, transcrip…
County scholarship procedures were approved
A private foundation proposed scholarships for people under age 26 from specified counties. Eligible applicants included local high school graduates, residents with disabilities seeking suitable train…
Foundation's employee matching gifts do not constitute self-dealing
A corporation that was the sole contributor to a private foundation planned to shift two employee matching-donation programs to the foundation in most jurisdictions. The corporation was a disqualified…
Foundation's employee matching gifts receive favorable excise-tax treatment
A private foundation planned to take over two employee matching-donation programs from its sole corporate contributor in most jurisdictions. The corporation was a disqualified person, but it had no le…
Foundation grants avoid excise taxes if expenditure responsibility is maintained
The IRS modified and superseded an earlier ruling concerning a private nonoperating foundation's proposed grants to a private operating foundation building a free community cultural center. The modifi…
Foundation may receive nonvoting LLC interests holding a related-party note
A foundation's founder planned for a revocable trust, at the founder's death, to give the foundation nonvoting interests representing 99 percent of the profits in an LLC whose sole asset was a note ow…
Foundation may receive nonvoting LLC interests holding a related-party note
A foundation's founder planned for a revocable trust, at the founder's death, to give the foundation nonvoting interests representing 99 percent of the profits in an LLC whose sole asset was a note ow…
Employer-related scholarship procedures receive advance approval
A private foundation proposed a scholarship program for children of U.S.-based employees of a related employer. An independent committee would select recipients using financial need, academic promise,…
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.