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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National security research grant procedures approved
A private foundation requested advance approval under IRC § 4945(g)(3) for grants supporting research on a country's long-term national security. Recipients would conduct research, build analytical sk…
Local student scholarship procedures approved
A private foundation requested advance approval under IRC § 4945(g)(1) for scholarships to local students attending an accredited community college, university, or trade school. Eligible applicants wo…
College and vocational grant procedures approved
A private foundation requested advance approval for two local grant programs. One program would fund degree study at qualifying post-secondary institutions under IRC § 4945(g)(1), while the other woul…
Primate conservation research grants approved
A private foundation requested advance approval under IRC § 4945(g)(3) for annual grants supporting nonhuman primate research and community-based conservation. Applicants would submit detailed proposa…
Foreign charitable grants receive favorable excise tax rulings
A private foundation proposed grants to two foreign charitable organizations that would independently select secondary grantees for projects serving disadvantaged elderly people, children, teenagers, …
Member and dependent scholarship procedures approved
A private foundation requested advance approval under IRC § 4945(g)(1) for five scholarships to members of an organization or their legal dependents who were graduating high school and entering higher…
Sculpture and writing grant procedures approved
A private foundation requested advance approval under IRC § 4945(g)(3) for two alternating grant programs. In odd years it would fund an artist creating a sculpture, and in even years it would fund a …
Early-career science fellowship and travel grants approved
A private foundation requested advance approval under IRC § 4945(g)(3) for research fellowships and travel grants benefiting early-career scientists. Fellowship grants would be paid to tax-exempt educ…
Vocational and trade school scholarship procedures approved
A private foundation requested advance approval under IRC § 4945(g)(1) for a scholarship program serving qualifying vocational and trade school students. Applicants must have graduated from public hig…
Need-based college scholarship procedures approved
A private foundation requested advance approval under IRC § 4945(g)(1) for scholarships helping financially needy students pursue higher education and career goals. Applicants must attend a community …
Five-year set-aside for an endowed professorship approved
A private foundation requested approval under IRC § 4942(g)(2) to accumulate funds over five years for an endowed distinguished chair at a university. The chair would specialize in two redacted fields…
Regional high school senior scholarship procedures approved
A private foundation requested advance approval under IRC § 4945(g)(1) for nonrenewable scholarships serving high school seniors in specified counties of two states. Applicants must pursue an accredit…
Scholarship procedures for students with disabilities received advance approval
A private foundation proposed scholarships for high school, college, and graduate students with intellectual or developmental disabilities who participated in a specified program. Recipients would be …
College scholarship procedures received advance approval
A private foundation proposed renewable scholarships for graduating high school seniors from specified counties who planned to enter four-year college programs. Eligibility included academic competiti…
Need-based college scholarship procedures received an IRS determination
A private foundation proposed full or partial college scholarships for financially needy students at specified religious high schools in a particular area. Selection considered school recommendations,…
Employer-related scholarship procedures received advance approval
A private foundation proposed nonrenewable scholarships for employees of a company group and their dependents who pursued undergraduate or graduate education. An independent committee would select rec…
Historic preservation matching grant qualified for set-aside treatment
A private foundation planned a matching grant to an organization restoring a historic property in a National Historic Landmark neighborhood. The grant would fund about one-third of the project's estim…
Historic property rehabilitation grant received set-aside approval
A private foundation planned a matching grant to rehabilitate a property listed on the National Register of Historic Places. The project covered interior and exterior features including plaster, finis…
Renewable postsecondary scholarship procedures received approval
A private foundation proposed scholarships for graduating seniors at a specified high school who were accepted to accredited two-year, four-year, or vocational programs. Selection considered grades, l…
Local high-school scholarship procedures approved
A private foundation proposed renewable, need-based scholarships for graduating seniors from high schools in one school district who would attend accredited colleges, universities, or trade schools in…
Kindness-based scholarship procedures approved
A private foundation proposed one-time scholarships for graduating high-school seniors entering accredited college degree or certificate programs. Participating schools would first operate a separate …
Scholarship and youth educational-grant procedures approved
A private foundation proposed two individual-grant programs. The first would provide nonrenewable scholarships to graduating seniors, selected primarily by financial need, academic performance, and ge…
Mission-aligned scholarship and skill grants approved
A private foundation proposed two mission-aligned grant programs. One would provide college or vocational scholarships to graduating high-school students whose planned studies fit the foundation's mis…
Scientific conference travel-grant procedures approved
A private foundation proposed grants for individuals with scientific expertise in preserving, protecting, and restoring a specified area to travel to academic and scientific conferences relevant to th…
IRS approved a private foundation's college scholarship procedures
A private foundation requested advance approval for a college scholarship program serving graduating high school seniors in a defined local area. Applicants must show academic achievement, financial n…
Dance scholarship and educational grant procedures approved
A private foundation proposed a one-time award program for students who have participated in dance. Recipients may use funds for books and tuition under the scholarship rules or for dance lessons, int…
Scholarship and educational grant procedures approved
A private foundation proposed two programs for United States citizens and legal residents. One program will fund undergraduate or graduate study, with payments made directly to educational institution…
Employer-related scholarship procedures approved
A private foundation proposed two scholarship programs for employees of a company. Each program will make one annual award to an employee who meets its academic and personal criteria, and an independe…
Historical research grant procedures approved
A private foundation proposed a program funding individual research projects about a city's history, culture, archaeology, architecture, and preservation. Applicants must propose defined work products…
Set-aside for domestic violence housing approved
A private foundation requested approval to set aside funds for additional transitional housing for women and children affected by domestic violence. The foundation already operates a housing program w…
International educational travel grants approved
A private foundation proposed an educational travel program for female students at rural high schools. The program will take a cohort outside the United States for cultural and educational activities,…
Scholarships for students facing disabilities approved
A private foundation proposed scholarships for graduating seniors at one high school who face a health, physical, or learning disability. Applicants must plan to attend a college, vocational, technica…
Agricultural career scholarships approved
A private foundation proposed annual scholarships for graduating students from one county who have been accepted to study for careers in agriculture. Applicants must provide contact information, proof…
Community project grant procedures approved
A private foundation proposed grants for community projects supporting economic viability, community building, and historic preservation in a town and nearby communities. Individuals, businesses, and …
Historic restoration matching-grant set-aside approved
A private foundation requested approval to set aside funds for a matching grant supporting restoration of ornamental plaster and murals at a historic property. The recipient organization must raise th…
Historic residency-site restoration set-aside approved
A private foundation requested approval to set aside funds for a matching grant to restore a historic property used as a residency site. The project includes masonry and exterior restoration, work on …
International dispute-resolution fellowships approved
A private foundation proposed fellowships for non-United States citizens to study dispute-resolution practices in the United States and apply them in their home countries. Applicants must be fluent in…
Three need-based scholarship programs approved
A private foundation proposed three programs serving students from low-income and resource-poor communities. One provides educational services and scholarship support during high school, another funds…
Regional four-year university scholarships approved
A private foundation proposed four-year scholarships for graduating seniors from specified under-resourced areas to attend either of two partner universities. Selection considers financial need, first…
Need-based medical school scholarships approved
A private foundation proposed one-time scholarships for students attending accredited medical schools in the United States. Applicants must document academic readiness, activities and experience, fina…
Employee-children merit scholarships approved
A private foundation proposed merit scholarships for children of employees of a company and its subsidiaries. An independent nonprofit will run the academic competition, select finalists, administer a…
Artist and nonprofit-leader grant procedures approved
A private foundation proposed two educational grant programs. One makes grants to artists at different career stages for artistic exploration and growth. The other funds sabbaticals for leaders of non…
Private foundation scholarship procedures approved
A private foundation requested advance approval for a scholarship program serving graduating high school seniors from specified school districts. Recipients would be selected using financial need, aca…
Historic-property matching grant set-aside approved
A private foundation proposed setting aside funds for a matching grant to restore a historic property used for educational programs and public tours. The grant would cover specified construction costs…
Historic-facility rehabilitation set-aside approved
A private foundation proposed setting aside funds for a matching grant to rehabilitate a historic facility under preservation standards. The recipient would raise the remaining project cost from other…
Employer-related scholarship procedures approved
A private foundation requested advance approval for scholarships offered to children and dependents of a company's full-time employees. Applicants would be evaluated using essays, community and school…
Sports and activity center set-asides approved
A private foundation requested approval to set aside funds over two fiscal years to construct a sports and activity center. The center would operate on a nonprofit basis for community youth activities…
STEM scholarship procedures received advance approval
A private foundation proposed annual scholarships for college-bound public, private, and home-school students in a specified county who would attend a four-year college or trade school. Its board woul…
Revised scholarship and study-travel grant procedures approved
A private foundation revised an existing program that awards scholarships and study-travel grants to high-achieving residents of a specified state who attend designated universities. Scholarship merit…
Educational facility renovation set-aside approved
A private foundation requested a set-aside to renovate a facility used for science, agriculture, arts, and music education for children and adults. The work included heating, ventilation, air conditio…
Employer-related scholarship procedures received advance approval
A private foundation proposed one-time scholarships for eligible dependents of employees of a company. An outside administrator would manage applications, due diligence, selection, payments to schools…
Scholarship procedures for underrepresented students approved
A private foundation proposed scholarships for historically underrepresented students in a metropolitan area who demonstrate academic excellence, community commitment, and plans to pursue four-year un…
IRS approves three need-based scholarship programs
A private foundation proposed three need-based scholarships. One would support a graduating scholar-athlete who planned to join a college athletic team, another would support a graduating student plan…
Archaeological-site construction set-aside approved
A private operating foundation asked to set aside funds for two buildings at an ancient archaeological site. One building would serve as a scientific laboratory, artifact-storage facility, and conserv…
Local merit-and-need scholarship procedures approved
A private foundation proposed renewable scholarships for graduating seniors from specified local high schools. Awards would be based primarily on academic performance and financial need, with recommen…
Three educational travel-grant programs receive advance approval
A private foundation requested advance approval for three programs that would pay or reimburse individuals' travel, lodging, meals, and related costs for educational events. The first program would br…
Degree and trade-school scholarship procedures approved
A private foundation proposed scholarships, apprenticeships, and fellowships for people pursuing degrees, certifications, or similar credentials at accredited colleges, universities, and trade schools…
Foundation scholarship procedures receive advance approval
A private foundation proposed renewable scholarships for low- to moderate-income students pursuing construction management, civil engineering, related fields, or vocational training. An independent co…
Private foundation received advance approval for two visual-arts grant programs
A private foundation proposed two nonrenewable grant programs for underrepresented early-career visual-arts professionals and artists. One program combines an unrestricted grant with mentoring, worksh…
Private foundation received advance approval for a public visual-art grant program
A private foundation proposed grants for visual artists to create or develop projects intended to be accessible to the public. Eligible uses include producing new work, researching concepts, acquiring…
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.