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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Private foundation scholarship procedures approved
A private foundation sought advance approval for a scholarship program serving graduates of a public high school. An independent school committee would nominate students, the foundation's trustees wou…
Employer-related scholarship procedures approved
A private foundation proposed scholarships for children of an employer's workers, participants in the foundation's vocational programs, and other qualifying applicants. An independent committee would …
Recycling grant qualifies, but free transfers cause self-dealing
A private foundation proposed an unrestricted grant to a public charity controlled by the foundation founder's granddaughter. The charity planned to buy recycling containers, collect waste, and transf…
Scientific research grant procedures approved
A private foundation proposed grants for individuals studying or researching scientific fields important to its charitable purposes. Selection would consider academic or professional achievement, rese…
Broad student scholarship procedures approved
A private foundation proposed scholarships for students completing high school, technical or community-college programs, undergraduate degrees, or advanced degrees. Applicants had to show academic abi…
Company-hosted youth job training will not be foundation self-dealing
A private foundation planned a job-training and education program for at-risk local youth. A related for-profit company, which was a disqualified person because it substantially funded the foundation,…
Musical-instrument apprenticeship grants receive advance approval
A private foundation proposed fellowships pairing accomplished musical-instrument builders with apprentices. The program would pay a stipend to each master for teaching time and a stipend for each app…
Arts scholarship procedures approved
A private foundation proposed renewable scholarships for graduating students from a specified high school who would pursue post-secondary education in the arts. Board members would select recipients b…
Community-leadership scholarship procedures approved
A private foundation proposed scholarships for students ages 13 through 25 who lived in one of seven counties and showed community leadership and volunteer service. A selection committee would conside…
Health-equity fellowship grant procedures receive advance approval
A private foundation proposed a one-year fellowship program to develop leaders who would advance health equity across a redacted geographical region. Applicants would be evaluated on leadership, profe…
Youth job-training grant procedures receive advance approval
A private foundation proposed a training and mentoring program for underserved young people who lacked basic job skills and work experience. Participants would receive classroom training, supervised p…
University research and public-service grant procedures receive approval
A private foundation proposed grants for activities benefiting gay and lesbian students, faculty, staff, and alumni at a university. The grants would cover research and conference travel, classwork or…
Regenerative-medicine research and surgical training grants receive approval
A private foundation developed grant programs supporting regenerative-medicine research and advanced training in oral, cranial, and maxillofacial surgery. Separate research tracks would fund residents…
Regional health-care scholarship procedures receive approval
A private foundation operated an endowed scholarship program for students from ten counties pursuing accredited health-care studies. Applicants had to be at least in their second year, maintain a mini…
Mismanaged charitable remainder trust faces income and excise taxes
A trust intended to qualify as a charitable remainder unitrust repeatedly included capital gains in trust income and paid more than its governing net-income limit permitted. The IRS concluded that the…
Failed charitable remainder trust owes tax before beneficiary payout
A trust intended as a charitable remainder unitrust paid beneficiaries more than its net-income limitation allowed by improperly treating capital gains as income. The IRS concluded that the trust fail…
Educational grant procedures receive advance approval
A private foundation requested advance approval of procedures for a grant program supporting innovative solutions in fields such as the arts, education, human rights, science, and technology. Applican…
Charitable remainder trust avoided split-interest trust rules because no deduction was taken
A grantor created a 20-year charitable remainder unitrust that pays the grantor during the term and then distributes the remainder to a tax-exempt charity. Although a charitable deduction could have b…
No-deduction charitable trust avoided split-interest trust rules
A charitable remainder unitrust pays the grantor, then another individual after the grantor's death, for at least 20 years before its remainder passes to a tax-exempt charity. The grantor represented …
Athletic scholarship procedures receive advance approval
A private foundation proposed an annual renewable scholarship for a student accepted by a college or university. Applicants had to maintain a B average, participate in varsity sports, and submit an es…
Private high school scholarship procedures receive advance approval
A private foundation proposed scholarships to help academically promising students pay tuition at private high schools. It would publicize the program through schools, churches, and electronic channel…
Performing arts scholarship and training grants receive advance approval
A private foundation proposed grants for high school juniors and seniors and college students pursuing careers in the performing arts. A knowledgeable selection committee would assess recordings, cour…
Local college scholarship procedures receive advance approval
A private foundation proposed two scholarships each year for local residents who attended a specified school district and were pursuing undergraduate or graduate education. Applicants would be evaluat…
Local high school graduate scholarship procedures receive advance approval
A private foundation proposed six annual scholarships for graduates of a specified high school who had at least a 2.5 grade point average and wanted to attend college or university. Applicants would b…
Broad educational scholarship procedures receive advance approval
A private foundation proposed scholarships for primary and secondary students, college and graduate students, and people pursuing vocational, artistic, or other accredited training. Trustees would cho…
Cultural center shops receive favorable foundation tax treatment
A private operating foundation planned a free community cultural center with museum exhibits, performance space, a library, an archive, a gift shop, and a coffee shop. The IRS found that the onsite co…
Scholarship procedures for children of fallen or disabled public safety officers are approved
A private foundation proposed scholarships for post-secondary or vocational education for children of city police officers and firefighters killed or disabled in the line of duty. A committee would se…
One-time community service scholarship procedures are approved
A private foundation proposed one-time scholarships for members of an affiliated company who were entering or continuing full-time undergraduate study. Independent community judges would evaluate appl…
Employer-related scholarship procedures are approved
A private foundation and another organization proposed scholarships for children of lower-paid employees of companies partly owned by the organizations' substantial contributors and their families. An…
Private foundation's need-based scholarship procedures are approved
A private foundation proposed scholarships for graduating high school seniors and certain recent graduates from a county who had not yet attended a postsecondary institution. Selection would consider …
Expanded scholarships for students from military families are approved
A private foundation asked to expand and revise a scholarship program serving students at selected military high schools. The expansion would also cover college-bound public-school seniors in Junior R…
International medical-training grant procedures are approved
A private foundation proposed expanding a medical-training grant program beyond liver-transplant education to recognized areas of medicine, medical care, and treatment. Grants could support doctors, n…
Scholarships for local student athletes are approved
A private foundation proposed tuition scholarships for public high school student athletes from a specified location who planned to attend accredited colleges or universities. Applicants would submit …
Pre-existing IP licenses qualify for indirect-self-dealing exception
A private foundation inherited intellectual-property rights in a long-running television show together with licensing agreements granting a company owned by Y exclusive rights to exploit those assets.…
IP licenses avoid self-dealing and passive royalty entities avoid excess holdings
A private foundation inherited intellectual-property rights in a long-running television show and agreements granting Y's company exclusive licensing rights. It proposed transferring the assets and ag…
Scholarship procedures receive advance approval
A private foundation proposed scholarships for U.S. students pursuing undergraduate or graduate degrees while working to advance American Muslim inclusion or reduce anti-Muslim discrimination. Applica…
Tuition-assistance procedures receive advance approval
A private foundation proposed tuition assistance for current students who might withdraw from a school because of financial hardship and prospective students whose families had not enrolled them becau…
Employer-related scholarship procedures receive advance approval
A private foundation proposed scholarships for children of lower-paid employees who had worked for a company for at least two years. An independent committee would select 20 to 30 recipients annually …
Employer-related scholarship procedures approved
A private foundation requested advance approval for two scholarship programs serving children of a company's employees. One program offered a renewable scholarship for full-time bachelor's degree stud…
Employer-related scholarship procedures receive approval
A private foundation proposed an employer-related scholarship program for eligible employees and their dependent children. A management company would administer the program and select recipients using…
Military-family scholarship procedures receive approval
A private foundation proposed an annual scholarship for a financially needy high school senior from a low- to average-income enlisted military family. Applicants needed strong academics and character,…
Foundation's paid data services further its charitable mission
A private operating foundation collected and analyzed neighborhood data to improve the lives of low-income children and their families. It proposed charging social-sector organizations reasonable fees…
Private foundation's scholarship procedures approved
A private foundation requested advance approval for a scholarship program serving students from kindergarten through graduate school. Recipients would be selected through interviews that considered fi…
Educational grant procedures for social justice leaders approved
A private foundation requested advance approval for a three-year educational grant program supporting individuals whose projects would advance social justice. A nominating committee would conduct pre-…
Scholarships for youth-program participants approved
A private foundation requested advance approval for scholarships benefiting financially needy high school seniors or equivalent students who participated in selected youth programs. Candidates would b…
Veterinary scholarships and research grants approved
A private foundation requested approval for grants supporting veterinary students' education and research on canine and feline health. Applicants would submit transcripts, recommendations, an essay, a…
Foundation grants avoid private-foundation excise taxes
A private nonoperating foundation proposed grants to a private operating foundation building and operating a free community cultural center. Two directors served on both boards, but they could not con…
Private foundation's three scholarship programs approved
A private foundation requested advance approval for three scholarship programs serving graduating high school students. The programs included a renewable bachelor's degree scholarship, a one-time awar…
Private foundation's scholarship program approved
A private foundation proposed scholarships for descendants of members of two chapters of a fraternal organization who attended a specified college. Applicants had to meet enrollment, course-level, and…
Employer-related scholarship procedures are approved
A private foundation proposed scholarships for current, retired, and former employees of an employer and its affiliates, as well as their spouses, children, and grandchildren. An independent selection…
Environmental research grant procedures are approved
A private foundation proposed fellowship grants for individuals conducting academic research on environmental protection and sustainability. A committee of trustees and recognized environmental expert…
Employer STEM scholarship procedures are approved
A private foundation proposed two-year scholarships for children of a company's employees who were pursuing community or technical college training for middle-skill STEM careers. An independent schola…
Teacher scholarship procedures receive advance approval
A private foundation requested advance approval of procedures for scholarships supporting college juniors, seniors, and graduate students majoring in elementary education. Applicants would be evaluate…
Employee children's scholarship program approved
A private foundation requested advance approval for scholarships offered worldwide to children of a company's employees. An independent third-party vendor would administer the program and select recip…
Sculptor conference grant procedures approved
A private foundation proposed grants for promising young sculptors to attend its annual conference. Each grant would cover a two-night hotel stay, waive the conference fee, and include a small stipend…
Jewish education scholarship procedures approved
A private foundation proposed a scholarship program to help converts to Judaism take college-level courses in Hebrew and Jewish studies. The awards would cover half of tuition and fees for up to four …
Journalism education grant procedures approved
A private foundation proposed grants for journalism students, working journalists, editors, news directors, and producers to study economics, business, jobs, and related subjects. Applicants had to at…
Supporting organization's business holdings were exempted from excise tax
A Type III non-functionally integrated supporting organization owned a development project that would become an excess business holding when statutory transition periods expired. The organization had …
Law student scholarship procedures received advance approval
A private foundation requested advance approval for a scholarship program serving second-year students at three qualifying law schools. Applicants would be evaluated by a committee using academic perf…
Restricted foundation grant would not be self-dealing
A private foundation proposed a grant to a supporting organization to construct and operate a performing arts center. The supporting organization planned to buy the site from a company that was a disq…
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.