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.
No determinations match these filters
Try a different search term or clear the filters.
Automatic member death benefits prevent charitable exemption
An organization serving members of specified immigrant communities applied for section 501(c)(3) status. Its activities included counseling, cultural events, aid to people in need, and payments to mem…
Captive insurer denied section 501(c)(15) exemption
A foreign captive insurance company claimed exemption under section 501(c)(15) for three tax years. It issued property and casualty contracts covering affiliated businesses and also participated in qu…
Endowment units do not create unrelated business taxable income
A charitable remainder unitrust proposed exchanging its assets for contractual units tied to a college's endowment after the college became sole trustee. The trust would have no ownership or control o…
College's endowment services do not create unrelated business income
A tax-exempt college proposed serving as trustee for charitable remainder unitrusts and issuing contractual units tied to its endowment. The trusts would receive payments based on the college's spendi…
Social club exemption revoked for recurring public income
A tax-exempt social club regularly opened some shooting facilities to the public and also sold calendars to nonmembers. The IRS examination found that the club repeatedly received more than 15 percent…
IRS revokes inactive charity that ignored records requests
An exempt organization did not respond to repeated IRS requests for records about its receipts, spending, and activities. The organization was inactive, with no operations or financial activities cond…
Charity loses exemption over property donation transactions
The IRS revoked an organization's section 501(c)(3) status effective January 1, 2009. The organization performed charitable work for schoolchildren, but it also accepted donated real estate at high st…
Farm employee housing foundation loses exemption
The IRS revoked a private foundation's section 501(c)(3) status because its primary activity was providing housing exclusively to employees of its founders' family-owned farming business. The foundati…
Captive insurer denied section 501(c)(15) exemption
A foreign captive insurance company sought exemption as a small nonlife insurance company under section 501(c)(15). The IRS examination concluded that most of its direct-written contracts covered busi…
Inactive charity lost its section 501(c)(3) exemption
The IRS revoked an organization's section 501(c)(3) exemption after finding that it had stopped conducting charitable work and had no regular operations or planned activities. The examination report s…
Church exemption revoked for private benefit and commercial activity
The IRS revoked an organization's section 501(c)(3) exemption after concluding that it no longer operated as a church and did not operate exclusively for exempt purposes. The examination found no esta…
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…
Large youth-program grant qualifies as an unusual grant
A public charity expected a large grant from an independent private trust to build a youth science, technology, and health center and support related operations. The charity had an active history of s…
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…
Restaurant and bar denied social-club exemption
An organization sought exemption as a social club under section 501(c)(7) while operating a bar and restaurant open to the general public. It advertised publicly, allowed anyone to buy food, and offer…
Business league exemption denied for member services
A cooperative health-care purchasing alliance of self-funded employers sought exemption as a business league under section 501(c)(6). It negotiated provider rates, managed provider contracts, coordina…
Cemetery's donation of church property is a charitable activity
A tax-exempt mutual cemetery company owned a historic church building and its approximately five-acre site. After restoring the church and preserving the site, the cemetery planned to donate both to a…
Terminating VEBA's member distributions avoid inurement but are wages
A voluntary employees' beneficiary association funded solely by mandatory payroll deductions voted to terminate and distribute its remaining assets to current and former employee members. Its formula …
Homeowners association loses social-welfare exemption
A homeowners association restricted membership to subdivision lot owners and used member assessments to maintain a lake, beaches, parks, and a tennis court, as well as limited member social activities…
Stock-car racing club denied charitable exemption
A stock-car racing organization already exempt under section 501(c)(4) sought charitable status under section 501(c)(3). Its governing documents expressly identified stock-car racing as its purpose an…
Inactive recovery-housing charity loses exemption
The IRS revoked the exemption of an organization formed to provide housing and support for people recovering from substance abuse. The examination found that the organization was inactive, reported no…
Food-bank charity loses exemption after failing to substantiate its operations
The IRS revoked the exemption of an organization formed to solicit and distribute surplus food and other items to people struggling to make ends meet. The organization reported cash and noncash contri…
Inactive educational organization loses exemption after bankruptcy
The IRS revoked the exemption of an educational organization that had planned supplemental programs for young people and a charter high school. The organization filed for Chapter 7 bankruptcy, and its…
Gaming and property activities disqualify public charity
The IRS revoked the exemption of an organization that conducted bingo games, sold pull tabs and scratch games, and maintained property used by a related fraternal organization. Although the organizati…
Closed private school loses exemption
The IRS revoked the exemption of a private school that had educated children from pre-kindergarten through eighth grade. The school experienced financial difficulties as enrollment declined, served a …
Inactive organ-recovery organization loses exemption
The IRS revoked the exemption of an organization formed to facilitate the recovery, processing, and distribution of human organs and tissue. The organization sold its fixed and cash assets and transfe…
Housing organization loses exemption after noncharitable operations
The IRS revoked the exemption of an organization originally formed for drug and alcohol prevention that later acquired and operated apartment complexes. The examination found that the housing operatio…
Daycare organization loses exemption over records and insider transfers
The IRS revoked the exemption of an organization that operated three full-time daycare facilities and participated in government-subsidized child-care and food programs. After repeated document reques…
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…
Farmers’ market is denied charitable exemption
An organization sought recognition as a tax-exempt charity under IRC § 501(c)(3) for operating a weekly farmers’ market and related educational events. The IRS found that the market’s substantial purp…
Foundation serving one individual loses charitable exemption
A foundation operated as a microboard providing care and support for one person with disabilities. The IRS examination found that all of the foundation’s activities, expenses, and earnings benefited t…
Title-holding company loses exemption for operating rental and bar services
A title-holding organization exempt under IRC § 501(c)(2) owned a building with offices and a banquet hall. It rented the hall to union members and the public and provided bar, bartender, and security…
Group is denied social-welfare exemption for an insufficient activity record
An organization applied for exemption under IRC § 501(c)(4) to promote a stated viewpoint through grassroots groups, candidate vetting, and public debates. Its only described activity was a forum for …
Dormant charity loses exemption for promoting a private tutoring business
A charity received exemption based on plans to help homeless and low-income people through tutoring, job support, and related programs. During examination, its representative said the organization was…
IRS denies social-club exemption for alcohol venue arrangement
An organization sought IRC § 501(c)(7) social-club exemption so it could obtain a private-club alcohol permit for an event venue owned by its president. Membership requirements were minimal, membershi…
Fee-based consulting organization denied charitable exemption
An organization sought exemption as a charity under IRC § 501(c)(3). It substantially provided consulting and administrative services for fees at or above cost. The IRS found that the organization had…
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.