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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Private foundation received advance approval for college scholarships to public-school graduates
A private foundation proposed renewable educational grants for graduating seniors from U.S. public high schools who had been accepted into four-year college programs. It initially planned four awards …
Private foundation received approval to set aside funds for a community arts facility
A private foundation sought to set aside a redacted amount to renovate four commercial properties into a public contemporary-art exhibition space. The facility will support local arts and cultural ini…
Private foundation received advance approval for grants to journalists and publishers
A private foundation proposed grants for experienced journalists and publishers pursuing an in-depth reporting activity identified by a redacted legend term. The program emphasizes free speech, dissen…
Private foundation received advance approval for scholarships to employees’ children
A private foundation proposed one-time, nonrenewable scholarships for dependent children of a company’s full-time employees. Eligible applicants must be no older than 24, have completed high school or…
Bilingual-teacher grant procedures received advance approval
A private foundation proposed two annual grant cycles for licensed K–5 Spanish-English bilingual teachers in specified communities. Teachers must have at least two years of relevant experience, spend …
Multi-focus scholarship procedures received advance approval
A private foundation proposed scholarships for students attending high school, college, graduate school, or vocational school, with focus areas covering animal welfare, education, Christianity, and su…
Community high-school scholarship procedures received advance approval
A private foundation proposed annual renewable scholarships for graduating seniors from a specified high school to encourage growth in the local community. Eligible students must plan to pursue postse…
Fine-artist grant procedures received advance approval
A private foundation proposed one-time grants to emerging and mid-career fine artists who are U.S. citizens or permanent residents and no longer students. Applicants must submit past work, a proposal,…
Foundation scholarship procedures approved
A private foundation asked the IRS to approve procedures for two scholarship programs serving economically disadvantaged students. One program offers nonrenewable awards to graduates of two specified …
Teaching and coaching grant procedures approved
A private foundation proposed grants for recent U.S. college graduates to spend a year teaching, coaching sports, and supporting students at a school outside the United States. A committee would recru…
Need-based county scholarship procedures approved
A private foundation proposed scholarships for graduating high school seniors from a specified county who plan to attend accredited postsecondary institutions. Applicants must show financial need and …
IRS pre-approves a company foundation's employee-children scholarship program
A private foundation tied to a company asked the IRS to pre-approve the way it will hand out scholarships to the children of the company's employees. This approval matters because a private foundation…
IRS approves a private foundation's scholarship award procedures
A private foundation asked the IRS to bless its scholarship program in advance under IRC § 4945(g)(1). This matters because grants a private foundation makes to individuals for study are normally "tax…
Foundation loans to a manager's own companies are self-dealing, private benefit, and jeopardizing investments
A private foundation, run solely by a married couple who were its only board members and officers, made many unsecured balloon loans totaling a large sum to two companies that one of the managers had …
Private foundation gets an extra five years to sell "excess business holdings" inherited from its founder
A private foundation cannot hold too large a stake in a business (an "excess business holding") without facing an excise tax under Section 4943, and it normally has five years to sell down after recei…
Advance approval of a private foundation's scholarship and educational-grant procedures under 4945(g)
This is an IRS letter giving a private foundation advance approval of the way it plans to award two kinds of grants to individuals. Private foundations face an excise tax on "taxable expenditures," an…
Letter 4797 (202501017): Approval of a private foundation's 4942(g)(2) set-aside to renovate and expand an affordable-housing complex
This is an IRS letter approving a private foundation's request for a "set-aside" under Section 4942(g)(2). Private foundations normally have to pay out a minimum amount each year for charitable purpos…
Foundation's scholarship and educational-grant procedures approved in advance
A private foundation that makes grants to individuals for study or travel normally owes an excise tax on those payments unless the IRS approves its grant-selection procedures in advance. Here a founda…
Healthcare scholarship procedures approved
A private foundation proposed scholarships for people from a specified area who enroll in health sciences professional schools. The program aims to increase the number of healthcare professionals serv…
Contemporary art grant procedures approved
A private foundation proposed grants for artists to create original artwork, writing, research, or projects inspired by the life and work of a redacted individual. Art experts would nominate candidate…
Merit-based scholarship procedures approved
A private foundation proposed scholarships for people under age 24 pursuing post-high-school education at universities, community colleges, technical schools, or vocational schools. Eligibility is tie…
Milestone-based youth scholarship procedures approved
A private foundation proposed scholarships for vulnerable and disadvantaged youth already participating in its charitable programs. The eligible group includes young people affected by child welfare, …
Public-interest-law fellowship grant procedures approved
A foundation proposed or expanded several grant programs for lawyers serving at section 501(c)(3) public-interest legal organizations. The programs cover professional licensing costs, law-school loan …
Scholarship procedures for graduating seniors approved
A private foundation proposed a scholarship program for graduating seniors from a specified school who pursue postsecondary education at an accredited technical school, community college, state school…
Professional artist grant procedures approved
A private foundation proposed grants to support the creative development and career advancement of professional artists who reside in a specified state. Applicants must have a significant body of orig…
Scholarship procedures for graduating high school seniors approved
A private foundation proposed scholarships for graduating high school seniors in a specified state who plan to attend accredited colleges full time. Applicants must meet academic and enrollment requir…
Scholarships for fatherless students at religious schools approved
A private foundation proposed scholarships for students whose fathers are deceased and who plan to attend private religious K-12 schools in two specified states. It will consider financial need, tuiti…
Employer-related STEM scholarship procedures approved
A private foundation proposed scholarships for children of a company's full-time and part-time employees who pursue four-year undergraduate degrees in science, technology, engineering, or math. An ind…
Scholarships for employees and their families approved
A private foundation proposed renewable scholarships for a company's employees and their spouses, dependent children, and grandchildren. Eligible recipients may attend undergraduate or trade and techn…
Scholarships for inner-city students and veterans' children approved
A private foundation proposed scholarships to help inner-city children and children of veterans with financial need and a strong showing of faith attend high school or college. Applicants must live in…
Sustainability scholarships and research grants approved
A private foundation proposed two programs related to environmental sustainability. The scholarship program will support undergraduate and graduate students studying environmental sciences, sustainabi…
Vocational scholarships for students overcoming obstacles approved
A private foundation proposed one-time scholarships for high school seniors who overcame significant educational obstacles and plan to attend accredited vocational or technical schools. Applicants mus…
Litigation-related contingent set-aside approved
A private foundation was subject to a court order requiring a fiduciary to hold distributions potentially owed to one beneficiary while litigation remained pending. The order permitted ordinary distri…
Skilled-trade scholarships for support-program students approved
A private foundation proposed scholarships for high school seniors who participated in a school elective that helps students address issues affecting their educational outcomes. Applicants must plan t…
Foundation's adversity scholarship procedures receive advance approval
A private foundation requested advance approval for scholarships benefiting high school students who overcame adversity and showed resilience and a desire to pursue college or graduate education. The …
Foundation scholarship procedures receive advance approval
A private foundation requested advance approval for a scholarship program serving graduating high school seniors from a particular community. Applicants must meet residency, school, financial-need, gr…
Psychiatry research fellowship procedures receive advance approval
A private foundation requested advance approval for two fellowship programs supporting research in child and adolescent psychiatry. One program supports early-career clinician-scientists, while the ot…
Heavy-construction scholarship procedures approved
A private foundation proposed two scholarship programs for undergraduate engineering or construction-management students interested in heavy civil construction. The first program is open to eligible s…
Regional research scholarship and grant procedures approved
A private foundation proposed one scholarship program for doctoral candidates and three grant programs supporting social science research and historical preservation in a specified region. The program…
Trust received five more years to sell excess business holdings
A split-interest charitable lead annuity trust received voting and nonvoting stock in a large international company through a bequest, creating excess business holdings under section 4943. The trust t…
IRS approves a company foundation's employer-related scholarship procedures
A private foundation asked the IRS to approve, in advance, the procedures it uses to award scholarships to the children of employees of a related company. This advance sign-off matters because IRC Sec…
IRS approves scholarship procedures for a foreign-education grant program
A private foundation asked the IRS to approve, in advance, the procedures it uses to award scholarships to disadvantaged children attending an accredited school in a foreign country. The advance appro…
IRS approves grant procedures for a program funding underrepresented entrepreneurs
A private foundation asked the IRS to approve, in advance, the procedures for a grant program that funds underrepresented and early-stage entrepreneurs. Under IRC Section 4945, a private foundation's …
IRS approves scholarship and grant procedures for three women's-education programs
A private foundation focused on advancing equity for women and girls asked the IRS to approve, in advance, the procedures for three programs: one set of career-development grants and two scholarship p…
Local college scholarship procedures approved
A private foundation proposed a scholarship program for residents of a specified county and state pursuing undergraduate, graduate, or vocational education. An outside administrator will publicize the…
Five scholarship programs approved
A private foundation asked the IRS to approve procedures for five scholarship programs serving students connected with two schools. The programs use academic, enrollment, school, community-involvement…
Scholarship and teacher grant procedures approved
A private foundation proposed a scholarship program for members of a federal credit union and a grant program for teachers nominated by students they had inspired. Scholarship applicants must document…
Need-based scholarship procedures approved
A private foundation proposed scholarships primarily for disadvantaged students from a specified central area of a state. Applicants must show financial hardship, educational commitment, state residen…
Lodge-purchase set-aside approved
A private foundation devoted to land and wildlife preservation requested permission to set aside funds to buy a rural lodge as its operating headquarters. It was negotiating with an owner whose asking…
Student scholarship and career grants approved
A private foundation proposed one-time grants to high school seniors who completed and remained in good standing with its multiyear youth leadership program. Recipients could use the grants for post-s…
Early undiscounted CLAT payments avoid foundation excise taxes
A charitable lead annuity trust had two required payments remaining for two private foundations before its remainder would pass to family trusts. Because the trust's investments had performed better t…
Early undiscounted CLAT payments avoid foundation excise taxes
A charitable lead annuity trust had two required payments remaining for two private foundations before its remainder would pass to family trusts. Because the trust's investments had performed better t…
Early undiscounted CLAT payments avoid foundation excise taxes
A charitable lead annuity trust had two required payments remaining for two private foundations before its remainder would pass to family trusts. Because the trust's investments had performed better t…
Early undiscounted CLAT payments avoid foundation excise taxes
A charitable lead annuity trust had two required payments remaining for two private foundations before its remainder would pass to family trusts. Because the trust's investments had performed better t…
Early undiscounted CLAT payments avoid foundation excise taxes
A charitable lead annuity trust had two required payments remaining for two private foundations before its remainder would pass to family trusts. Because the trust's investments had performed better t…
General education scholarships approved
A private foundation proposed at least a specified number of annual scholarships for deserving students to pursue general education, vocational training, or professional study. High school seniors, gr…
Four-year college scholarships approved
A private foundation proposed renewable four-year scholarships for graduating students at a specified high school, with possible expansion to schools in nearby counties. Applicants had to be admitted …
Employer-related scholarships approved
A private foundation proposed scholarships for an employer's workers and their dependent children to attend vocational schools, community colleges, or universities. An independent committee with no em…
Foundation's scholarship and neuroscience grant procedures received advance approval
A private foundation requested advance approval for two programs that make grants to individuals. One program provides scholarships for K-12, college, or graduate students' tuition and related educati…
Advance approval of a private foundation's scholarship procedures
A private foundation asked the IRS to pre-approve how it will award college scholarships. This approval matters because a private foundation's grant to an individual for study is normally a "taxable e…
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.