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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IRS approves an arts relocation set-aside
A private foundation asked to set aside funds over five years to help a foreign arts organization relocate its museum operations to another city. The organization had not yet found a suitable site, la…
IRS approves a science fellowship grant program
A private foundation sought advance approval for a fellowship program intended to increase women's participation in science and engineering at universities in a foreign country. Eligible applicants we…
IRS approves university scholarship procedures
A private foundation requested advance approval for several scholarship programs serving students who were active at a university student center. Award amounts depended on financial need and available…
IRS approves trade school and college scholarship procedures
A private foundation requested advance approval for a scholarship program serving high-achieving graduating students who were active in extracurricular and community activities. Recipients could use t…
Foundation's biomedical research grant procedures approved
A private foundation proposed four grant and fellowship programs supporting early-stage biomedical research intended to benefit children in the United States. Participating institutions would nominate…
Scholarship grant procedures receive advance approval
A private foundation requested advance approval of procedures for educational grants to people facing financial hardship or other barriers. The program would use objective, nondiscriminatory selection…
Volunteer scholarship procedures receive advance approval
A private foundation proposed one-time scholarships for high school seniors who volunteered and demonstrated social responsibility and civic engagement. Applicants also had to meet a minimum grade-poi…
Four scholarship programs receive advance approval
A private foundation proposed four scholarship programs for different groups of college and university students, including study-abroad participants and students at specified institutions. Outside org…
Cultural travel grant procedures receive advance approval
A private foundation proposed grants enabling students, faculty, and other qualified individuals to deepen their study of a foreign culture through travel. Faculty nominators would identify candidates…
Private foundation's scholarship procedures receive advance approval
A private foundation proposed annual scholarships for students in good standing at accredited higher-education institutions in the United States and abroad. Recipients would be chosen based on financi…
Local high-school scholarship procedures receive advance approval
A private foundation proposed ten one-time scholarships for high-school seniors from a specified city who planned to attend four-year colleges or universities. Schools would submit application package…
Foundation receives five more years to sell business holdings
A private foundation inherited all the stock of a company whose interests in development joint ventures became excess business holdings. The foundation tried to dispose of the company during the initi…
Foundation's research conference grants approved
A private foundation proposed grants for researchers and scholars to attend academic and scientific conferences, report how the material applied to diabetes research, and help identify potential grant…
Modified county scholarship procedures approved
A private foundation modified an existing scholarship program for county residents attending tax-exempt postsecondary schools. It publicized the program through local school districts, its website, an…
Health-care scholarship procedures receive advance approval
A private foundation proposed multiple scholarship programs for people pursuing nursing, medical, and related health-care education. Applicants had to demonstrate academic ability, character, citizens…
IRS approves a private foundation's scholarship procedures
A private foundation asked the IRS to approve procedures for two types of educational scholarships. The program would use stated academic, service, essay, and, for one award, financial-need criteria, …
Public-interest law fellowship procedures approved
A private foundation proposed fellowships for graduating law students to work for nonprofit organizations providing civil legal services to people with low incomes or those deprived of civil or human …
Public-policy fellowship grant procedures approved
A private foundation proposed grants for full-time, ten-week fellowships related to national and international public policy. Several programs targeted applicants with specified military-service, educ…
School-based scholarship procedures receive advance approval
A nonexempt charitable trust asked the IRS to approve procedures for scholarships benefiting graduates of two schools who would attend one of two designated post-secondary schools. Applicants had to m…
Inherited rental properties avoid UBIT and private-foundation excise taxes
A private foundation expected to inherit commercial rental properties through single-member limited liability companies and planned to use another disregarded LLC to manage them. The IRS ruled that qu…
IRS approves artist residency grant procedures
A private operating foundation sought advance approval for grants and stipends paid to participants in its arts, literature, and science residency program. Residents are selected nationally by an exte…
IRS approves employee-child scholarship procedures
A private foundation proposed six one-time college scholarships for children of its employees and subsidiaries' employees. An independent organization would select recipients through a national academ…
IRS approves scholarship and fellowship procedures
A private foundation proposed scholarships based on financial need or academic excellence and fellowships supporting academic, literary, artistic, and related work. Scholarship applicants could attend…
IRS approves need-based college scholarship procedures
A private foundation proposed one-time college scholarships for students selected by participating schools. A school had to be a commercial customer of a specified bank and have more than half of its …
IRS approves set-aside for water-quality education facility
A private foundation asked to set aside funds to construct a larger facility for two water-quality and science education programs. The planned building would include chemistry and biology teaching lab…
IRS approves a long-term set-aside for a STEM student-debt program
A private foundation proposed setting aside a redacted amount for a program that would reduce student debt for selected workers who committed to living and working in one state in STEM occupations for…
IRS approves nonprofit executive sabbatical grants
A private foundation proposed sabbatical grants for executive directors and chief executive officers of public charities providing health-related services. The grants would fund salary, travel, housin…
IRS approves expanded health-workforce fellowships
A private foundation proposed expanding its fellowships beyond traditional health professionals, faculty, and scholars to a broader range of people working to improve health and healthcare. Fellows wo…
IRS approves renewable need-based college scholarships
A private foundation proposed scholarships for academically qualified high school seniors with financial need who planned to attend eligible four-year colleges in their state. Awards could cover tuiti…
IRS approves first-semester scholarships for high school graduates
A private foundation proposed scholarships for graduates of a particular high school who would attend college or trade school. Applicants needed at least a 3.0 grade point average and would be evaluat…
IRS approves scholarships for students with disabilities
A private operating foundation proposed scholarships to help students with disabilities attend an eligible educational institution. Financial need, recommendations, enrollment, tuition costs, other ai…
IRS approves a private foundation's college scholarship procedures
A private foundation proposed awarding one annual scholarship to an incoming college freshman from a specified area who would attend a nonprofit college. Applicants would need a GPA of at least 3.0, v…
A foundation received 60 days to perfect conduit elections
A private foundation intended to qualify as a conduit foundation by treating prior excess qualifying distributions as current distributions out of corpus. Its return preparer calculated carryovers con…
A uniform stock redemption avoided private-foundation self-dealing
A private foundation owned nonvoting shares in a closely held company that was a disqualified person, along with shares in a related domestic international sales corporation. The two corporations prop…
A uniform DISC stock redemption avoided self-dealing
A private foundation owned voting shares in a closely held domestic international sales corporation that was a disqualified person, along with nonvoting shares in a related company. The two corporatio…
Field-science scholarship procedures received approval
A private foundation proposed annual scholarships for undergraduate and graduate students pursuing field-focused science, technology, engineering, and mathematics careers. Applicants had to meet acade…
University scholarship procedures received advance approval
A private foundation with a financial institution as trustee proposed scholarships for full-time students at a specified university. Applicants needed academic merit, financial need, and good characte…
Local high-school scholarship procedures received approval
A private foundation proposed fewer than five scholarships each year for local high-school graduates attending recognized educational institutions full time. A selection committee would evaluate acade…
Employee-dependent scholarship procedures received approval
A private foundation proposed scholarships for dependents of a company's employees to attend accredited undergraduate or technical programs. An independent, education-focused committee would select re…
Scholarship and career-experience grant procedures approved
A private foundation proposed two programs for high school students. One would help graduating seniors buy computers, textbooks, or other post-secondary educational materials, while the other would fu…
IRS approved fellowship and project-award procedures
A private foundation proposed a nine-month educational program for young adults that combined retreat sessions, study, reflection, and development of a practical project idea. Fellowships would cover …
Private foundation’s fellowship and educational grant procedures approved
A private foundation requested advance approval for a grant program supporting study, research, writing, teaching, publications, travel, and other projects related to its charitable mission. Applicant…
Regional scholarship, educational grant, and loan procedures approved
A private foundation sought approval for scholarships leading to undergraduate and graduate degrees, grants for nondegree education, and possible future low-interest educational loans. Applicants need…
IRS approves scholarships for students connected to grantee organizations
A private foundation proposed scholarships for high school graduates and GED recipients affiliated with its current or former grantee organizations. Awards would support up to four years at an accredi…
IRS approves education and professional-development grants for teachers and school leaders
A private foundation proposed grants to help high-performing teachers, school leaders, and other education-focused individuals pursue training, certification, advanced degrees, conferences, or educati…
Private foundation’s scholarship procedures receive advance approval
A private foundation proposed renewable scholarships for eligible high school seniors and college students pursuing undergraduate degrees at nonprofit colleges in the United States. Recipients would b…
Employer and public scholarship procedures receive advance approval
A private foundation proposed two nonrenewable scholarship programs, one for eligible employees of a related employer and another open to eligible members of the general public. An independent selecti…
Electrical-engineering scholarship procedures receive advance approval
A private foundation proposed an annual, nonrenewable scholarship for a first-year graduate student in electrical engineering at a recognized United States engineering school. A designated committee w…
University scholarship procedures receive advance approval
A private foundation proposed scholarships for full-time students in good standing at a Christian university, funded by income from donor-restricted permanent funds. Applicants would submit a narrativ…
Area high-school scholarship procedures receive advance approval
A private foundation proposed one nonrenewable scholarship for each high school in an organization’s membership area. Eligible graduating seniors would be evaluated using grades, test scores, activiti…
Mining-related scholarship procedures receive advance approval
A private foundation requested advance approval for merit scholarships available to a corporation's shareholders, their dependents, and descendants of shareholders. The program supports full-time stud…
Engineering and science scholarship procedures receive advance approval
A private foundation requested advance approval for a scholarship program serving graduating seniors from three local high schools. Applicants must have at least a 3.0 grade point average, plan full-t…
Long-term care scholarship procedures receive advance approval
A private foundation proposed scholarships for employees of long-term care facilities who were accepted into nursing or related education programs. An independent selection committee would evaluate ap…
Scholarship procedures for heritage and faith communities approved
A private foundation proposed a scholarship program for students connected to specified heritage and faith communities who would study at qualifying schools in the United States or a redacted country.…
Scholarship and educational grant procedures receive advance approval
A private foundation proposed scholarships for students attending qualifying educational programs and grants for young people developing career-related skills or talents. Applicants would be evaluated…
Art travel grant procedures receive advance approval
A private foundation proposed grants covering travel costs for international art professionals to visit a country, meet contemporary artists and other art professionals, and visit artistic and cultura…
Foundation receives approval for martial arts grant procedures
A private foundation proposed grants to individuals for martial arts, self-defense, and anti-violence training, travel, competitions, certifications, and educational publications. Applicants would be …
Foundation's university scholarship procedures receive advance approval
A private foundation proposed scholarships for qualifying members of a university chapter who needed tuition assistance. An independent selection committee would consider academic standing, financial …
Private foundation division approved with pass-through conditions
A family private foundation proposed transferring 40 percent of its assets equally to two new private foundations so different family branches could pursue separate charitable priorities. The IRS rule…
Three scholarship programs receive advance approval
A private foundation requested advance approval for the procedures used by three scholarship programs. The programs generally support qualifying students, many of whom are pursuing teaching degrees, a…
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.