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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College endowment units do not create UBTI for charitable remainder trust
A charitable remainder unitrust proposed exchanging assets for contractual units tied to the pooled endowment of the college serving as its trustee and remainder beneficiary. The units would provide p…
Cost-only endowment management creates no UBTI for college
A tax-exempt college proposed issuing contractual units in its pooled endowment to a charitable remainder trust for which it was trustee and sole charitable remainder beneficiary. The trust would rece…
Purchasing and rebate services did not qualify as business-league activity
An organization claimed exemption as a section 501(c)(6) business league without having applied for recognition from the IRS. Its principal activities were negotiating bulk purchases and vendor rebate…
Commercial pipe manufacturing did not qualify as charitable activity
A nonprofit successor to a for-profit business proposed developing machinery and manufacturing large corrugated metal pipes for bridges, overpasses, and disaster-recovery projects. It planned to sell …
Bingo operations and related-party rent defeated charitable exemption
A public charity regularly operated bingo and pull-tab games three days each week and used part of the proceeds for grants. The IRS found that gaming consumed nearly all of the organization's income, …
Regional chamber is denied section 501(c)(3) status
An organization already exempt under section 501(c)(6) applied to be recognized under section 501(c)(3). It promoted local businesses and tourism, published member business information, made referrals…
Building-management company is denied section 501(c)(10) status
A limited liability company wholly owned by a section 501(c)(10) fraternal organization applied for its own exemption under that provision. The company maintained a building used by its owner and othe…
Exclusive referral network is denied business league exemption
A networking organization limited membership to one representative from each business or profession and required members to remain exclusive to the group. Members met weekly, tracked business referral…
Fraternal society lost exemption after failing to provide records
A fraternal beneficiary society had long been recognized as exempt under section 501(c)(8). During an examination, the IRS repeatedly requested records about the society's receipts, expenditures, acti…
Fee-based software and support services prevented charitable exemption
An organization sought section 501(c)(3) status to support independent community journalism through education, mentoring, administrative help, and an open-source publishing platform. It planned to hel…
Therapy-dog visits further charitable purposes
A section 501(c)(3) research institute proposed a free pet-therapy program for hospital patients, particularly children, and elderly nursing-home residents. Registered, health-certified therapy dogs w…
Single-brand advertising group loses exemption
An organization of franchisees for one brand collected member fees and ran a common marketing and advertising program designed to increase awareness, customers, sales, and profits. The IRS concluded t…
School support association denied exemption
An association raised money to buy supplies and equipment for a for-profit S corporation school owned by the association's president. The school was the association's only intended recipient, several …
Recreational archery club denied section 501(c)(3) status
An archery club already exempt under section 501(c)(4) applied for section 501(c)(3) status. Its organizing document broadly authorized operating an archery club, and its dissolution clause did not pe…
Exemption revoked after audit noncooperation
The IRS audited a public charity and found that its articles lacked adequate exempt-purpose and dissolution clauses. The IRS repeatedly requested descriptions of the organization's activities, financi…
Donor-directed student-loan payments served private interests
An organization created a website through which borrowers could register their federal student loans and seek donations toward repayment. Sponsors could direct contributions to particular borrowers or…
Open-source software organization is denied section 501(c)(3) status
An organization developed and promoted a particular free and open-source software project. It held conferences, maintained educational resources, supported volunteer development, and received most of …
Burial-assistance association is denied fraternal exemption
An association collected membership fees and special contributions to help pay burial costs when a member died. It also planned membership meetings and classes on funeral planning and topics useful to…
Automobile dealer advertising association loses business-league exemption
An association coordinated and funded advertising for a limited group of automobile dealers in a designated market area. Member contributions paid for television, radio, newspaper, digital, and other …
Adult baseball league loses charitable exemption
A nonprofit operated an adult men's baseball league and charged team membership fees. Its activities centered on league play, game administration, statistics, prizes, playoffs, and an all-star game, w…
Nonprofit loses exemption after failing to provide audit records
A section 501(c)(3) organization was selected for an audit of a Form 990-N filing. The IRS sent repeated letters to the organization and several officers, and it made multiple telephone calls, but the…
Nonprofit loses exemption after ignoring record requests
A section 501(c)(3) organization was selected for an audit of a Form 990-N filing. The IRS mailed examination requests to the organization and several officers and repeatedly called its director and s…
Inactive nonprofit loses charitable exemption
A nonprofit had previously been automatically revoked for failing to file annual returns and was later reinstated as a section 501(c)(3) organization. During a later examination, the IRS found that th…
Electronic-waste facility loses tax-exempt status
An organization operated an electronic-waste disposal facility. The IRS found that it had not demonstrated that it operated exclusively for charitable, educational, or another exempt purpose. It there…
Deer-herd loss plan denied agricultural exemption
A membership organization sought exemption as an agricultural organization under IRC § 501(c)(5). Its members would contribute money after covered deer-herd losses so the affected member could recover…
Apartment rentals to the public caused exemption revocation
The IRS revoked a nonprofit organization's exemption under IRC § 501(c)(3). During the examined years, the organization's only observed activity was renting its facility as apartments to members of th…
Failure to provide audit records led to exemption revocation
The IRS revoked a private foundation's exemption under IRC § 501(c)(3). The organization had stopped operating, had not filed required Form 990-PF returns for multiple years, and did not provide the r…
Community organization loses exemption for social and recreational activities
A community organization said its mission was to improve quality of life through economic development, community and cultural activities, and educational advancement. Its activities included a two-day…
Single-company insurance agents are denied business-league exemption
An association was formed for independent agents who sold insurance and financial products offered by one company. It planned education, training, networking events, and an annual awards banquet, all …
Dissolved organization lost exemption after ignoring audit requests
The IRS revoked an organization's exemption under IRC § 501(c)(3). The organization filed short Form 990-N notices, but those filings did not establish that it was conducting exempt activities. It als…
Back-health nonprofit is denied exemption for benefiting related insiders
A nonprofit proposed teaching a proprietary muscle-management program intended to reduce back pain. A related for-profit company owned by the nonprofit's president held the program's intellectual prop…
Record collectors' sales show does not qualify as a charity
A record collectors' club held monthly meetings and operated a large annual show where dealers rented tables and sold records, CDs, and memorabilia. Members received early access to the dealers, and t…
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…
Captive insurer loses section 501(c)(15) exemption
A foreign captive insurance company claimed exemption as a small property and casualty insurer under section 501(c)(15). The IRS found that most direct-written contracts covered business or investment…
Captive insurer loses section 501(c)(15) exemption
A foreign captive insurance company claimed exemption as a small property and casualty insurer under section 501(c)(15). The IRS found that the company's direct-written contracts concentrated risk in …
Branch-franchise applicant denied charity status over commercial and political concerns
A nonprofit applied for section 501(c)(3) status to conduct research and public education on environmental, social, and economic issues. Its website also promoted a fee-based franchise model for affil…
Captive insurer denied section 501(c)(15) exemption because most contracts were not insurance
A foreign captive insurer claimed exemption under section 501(c)(15) for four tax years after withdrawing an earlier exemption application. It issued property and casualty contracts to affiliated busi…
Civic education group denied charity status for partisan campaign activity
A volunteer civic group applied for exemption under section 501(c)(3), describing educational programs about government, public policy, and the Constitution. Its articles also allowed any lawful activ…
Charity status revoked over uncontrolled sponsorships and noncharitable activity
The IRS revoked a charity's section 501(c)(3) status after concluding that it could not show its cash disbursements were used exclusively for charitable purposes. The organization acted as fiscal spon…
Captive insurer denied exemption for insufficient insurance risk and distribution
A foreign captive company claimed exemption as a small property and casualty insurer under section 501(c)(15). The IRS found that only one of the direct-written contracts it reviewed covered an insura…
Historic church property transfer qualifies as an unusual grant
A cemetery association proposed transferring a historic church site and native prairie to a related public charity formed to preserve the property and provide educational programs. The property's valu…
Project-development corporation is denied 501(c)(3) status
A corporation applied for 501(c)(3) status to design and manage educational, scientific, technological, and business projects. The IRS repeatedly requested concrete details about its activities, parti…
Facility-rental organization loses 501(c)(3) status
An organization received 501(c)(3) status to promote economic and community development and support programs serving senior citizens and people with disabilities. An IRS examination found that the org…
School health-benefit trust loses 501(c)(4) status but keeps section 115 exclusion
A trust formed by public school entities purchased and later self-insured health benefits for employees of participating school districts. The IRS concluded that the trust did not qualify under sectio…
Religious publisher is denied 501(c)(3) status
A nonprofit corporation applied for 501(c)(3) status to publish and market religious books and resources. It charged authors subvention fees, paid royalties, sold books through commercial channels, an…
Firearms organization loses 501(c)(3) status
A firearms-focused organization originally held section 501(c)(4) status and later received recognition under section 501(c)(3) after amending its stated purposes. During an examination, it reported m…
Rental activity and a for-profit asset transfer cost exemption
A trust recognized under section 501(c)(3) and classified as publicly supported under section 509(a)(2) was examined after it incorporated and later terminated. Its support came primarily from renting…
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…
Exemption revoked after nonresponse and corporate dissolution
A section 501(c)(3) organization did not provide records requested during an IRS examination and had not filed required Form 990-series returns for several years. Its state corporate status had also b…
Exemption revoked after educational activities stopped
An exempt school lost its primary public-school funding and stopped serving students or conducting educational programs. It then rented parts of its property to food trucks, a day care center, and a w…
Exemption revoked after residential care activities ended
A section 501(c)(3) organization had provided housing and support services for people living with AIDS through public health contracts. After losing those contracts, it stopped providing those service…
Public golf course does not qualify as an exempt social club
A nonprofit golf course sought exemption as a social club under section 501(c)(7). The course and clubhouse were regularly open to the public, nonmembers generated more than 25 percent of receipts, an…
Professional rodeo association does not qualify under section 501(c)(3)
A membership association conducted about fourteen rodeos each year, charged participants entry fees, charged spectators admission, and awarded cash prizes. Its bylaws emphasized promoting professional…
Dealer advertising cooperative loses section 501(c)(6) exemption
A self-declared association of automobile dealerships pooled dealer contributions to fund advertising for vehicles from one manufacturer in a defined television market. The IRS concluded that the asso…
Transportation LLC is denied charity status for private benefit and commercial operations
An LLC sought section 501(c)(3) status to provide scheduled transportation to people with disabilities and other clients affected by local budget cuts. It shared vehicles, drivers, an address, and an …
Housing general partner is denied exemption for benefiting for-profit owners
An organization served as the one-percent general partner of a limited partnership that owned a 32-unit apartment building. The remaining partnership interests were held by a for-profit LLC and two in…
Large grant from unrelated foundation qualifies as an unusual grant
A publicly supported charity serving at-risk youth and foster children sought a large grant from a newly formed private foundation to expand programs addressing teen homelessness. The grant was expect…
Health-care membership and VEBA organization denied exemption
A membership organization sought recognition as both a section 501(c)(3) charitable and educational organization and a section 501(c)(9) voluntary employees' beneficiary association. It offered health…
Condominium business park does not qualify as an employee-benefit association
A condominium business park sought exemption as a voluntary employees' beneficiary association under section 501(c)(9). Its members joined by purchasing condominium units, and membership was not volun…
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.