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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Employee-child scholarship procedures receive advance approval
A private foundation requested advance approval for scholarships benefiting dependent children of a company's full-time employees. An independent nonprofit selection committee would evaluate eligible …
Environmental research grant procedures receive advance approval
A private foundation requested advance approval for grants supporting research into sustainable and environmentally friendly ranching, forestry, and farming practices. Staff would identify qualified r…
Employee scholarship procedures receive advance approval
A private foundation proposed scholarships for store-level employees of a related organization who were pursuing college degrees. Eligible employees needed at least one year of service, specified week…
Foundation's campus construction set-aside is approved
A private foundation requested approval to set aside funds toward construction of a campus for a tax-exempt college and the surrounding community in an economically depressed area. The multiyear proje…
Humanities fellowship grant procedures are approved
A private foundation proposed a fellowship program supporting humanities scholars who create public-facing projects such as books, documentaries, curricula, and educational websites. Participating col…
Private foundation split receives favorable tax rulings
A private foundation whose directors disagreed about how to carry out its mission proposed transferring half of its cash and publicly traded securities to a second private foundation. The IRS ruled th…
Medical research grant procedures receive advance approval
A private foundation proposed grants to researchers at universities, hospitals, and research centers for work on heart disease, cancer, AIDS, and similar diseases. The program would be publicized onli…
Revised employee scholarship procedures receive approval
A private foundation revised an existing scholarship program for dependent children of a related employer's full-time employees. Nonrenewable awards would pay qualified tuition, fees, books, and suppl…
Private foundation may receive most of a related foundation's assets
A private foundation asked about receiving approximately 78 percent of another private foundation's net assets after the transferor's directors disagreed about how to carry out its charitable purposes…
Foundation may transfer most assets subject to distribution safeguards
A private foundation proposed transferring approximately 78 percent of its net assets to another commonly controlled private foundation while continuing its own charitable work with the remaining asse…
Foundation may buy out partners in low-income housing LLC
A private foundation that managed an affordable-housing LLC proposed buying the interests of the LLC's investor and special members, leaving the foundation as sole owner. The IRS ruled that the housin…
IRS approves scholarship program for low-income urban students
A private foundation proposed a scholarship program for low-income graduates from specified counties who planned to attend accredited four-year colleges or universities. Applicants had to meet financi…
Foundation's grants to artists and teachers approved
A private foundation requested advance approval for a grant program serving artists and teachers in a metropolitan area. Applicants would be evaluated on financial need, prior achievement, motivation,…
Foundation scholarship procedures approved
A private foundation requested advance approval for scholarships supporting needy undergraduate and graduate students in a metropolitan area. Its board would select recipients based on financial need,…
Graduate educational travel grants approved
A private foundation proposed expanding an existing graduate fellowship program to fund educational travel in the United States and abroad. Applicants would submit travel plans and educational goals, …
Artist development grant program approved
A private foundation proposed a program providing artists with grants and industry resources for research, retreats, drafting, workshops, short works, and other professional development. Candidates wo…
Dental scholarship procedures approved
A private foundation requested advance approval for scholarships supporting students in dental assistant training and other dental professions. Applicants would be evaluated using financial need, inte…
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.