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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Advance approval of a private foundation's arts fellowship grant procedures
A private foundation asked the IRS to pre-approve how it will hand out fellowship grants to individual artists. This step matters because when a private foundation gives money to an individual for tra…
IRS approves a foundation's grant program for visual artists who overcame life disruptions
A private foundation asked the IRS to approve, in advance, the procedures for a grant program supporting visual artists in a particular area who returned to making art after significant life disruptio…
IRS approves a foundation's medical-school scholarship and research-grant procedures
A private foundation whose charitable focus includes health care and education asked the IRS to approve, in advance, the procedures for two programs: a scholarship program for medical students and a g…
Five more years granted to a charitable trust to sell excess business holdings in a niche company
Private foundations (and trusts treated like them) generally cannot own more than a small slice of a business, and if a large stake lands in their hands by gift or inheritance they get five years to s…
IRS approves an employer-related scholarship program for employees' children
A private foundation asked the IRS to approve, in advance, an employer-related scholarship program that funds college for the children of a company's employees. Under Section 4945, a foundation's gran…
IRS approves a foundation's scholarship procedures for disadvantaged children abroad
A private foundation asked the IRS to approve, in advance, how it will award scholarships. Under Section 4945, a foundation's grants to individuals for study are normally "taxable expenditures" that t…
IRS approves a foundation's grant procedures for funding underrepresented entrepreneurs
A private foundation asked the IRS to approve, in advance, how it will pick and oversee grants to individuals. This matters because Section 4945 taxes a foundation's "taxable expenditures," and grants…
Advance approval of scholarship procedures for gifted, underprivileged students
A private foundation asked the IRS to pre-approve the way it will award college and graduate-school scholarships. Because a private foundation that makes grants to individuals for study normally owes …
Advance approval of a foundation's tuition scholarship procedures for students abroad
A private foundation asked the IRS to pre-approve how it will select and pay scholarships. A private foundation that gives individuals money for study normally owes an excise tax under Section 4945 un…
Advance approval of a private foundation's rural-focused scholarship procedures
A private foundation asked the IRS to pre-approve the way it will pick and pay scholarship recipients. This approval matters because a private foundation that makes grants to individuals for study nor…
Private foundation scholarship procedures received advance approval
A private foundation sought advance approval for a scholarship program serving financially needy students pursuing higher education. The program emphasizes fields such as science, technology, engineer…
Student support scholarship procedures received advance approval
A private foundation sought advance approval for a scholarship program that gives additional financial support to students pursuing post-secondary education. Eligible applicants generally come through…
Scholarship procedures for members and relatives approved
A private foundation asked the IRS to approve a scholarship program for eligible current, former, and retired members of an organization and their qualifying relatives. Applicants must be accepted by …
Rural community project grant procedures approved
A private foundation asked the IRS to approve two programs that make grants to individuals addressing quality-of-life problems in rural communities. One program funds discrete volunteer-led community …
Sculpture-garden construction set-aside approved
A private foundation requested permission to set aside funds for a major redesign of a large urban sculpture garden it had previously helped create. The project would unify the garden, add walkways, p…
Athlete and employee scholarship procedures approved
A private foundation asked the IRS to approve two scholarship programs. The first awards four nonrenewable scholarships to high-achieving graduating student athletes in one state, using academic, athl…
Scholarship procedures for members' children received advance approval
A private foundation proposed scholarships for children of members of a statewide society who attend undergraduate or graduate programs. Applicants must meet academic, enrollment, Selective Service, t…
Skilled-trade scholarship and educational-grant procedures approved
A private foundation proposed scholarships and educational grants for graduating high school seniors pursuing skilled-trade programs, vocational schools, technical training, or apprenticeships. Applic…
Scholarship procedures for veterans' and first responders' children approved
A private foundation proposed scholarships for children of veterans and first responders in a defined geographic area. The awards would support two-year or four-year undergraduate study or qualifying …
Foundation's building-renovation set-aside was approved
A private foundation that supports criminal-justice and youth-justice reform asked to set aside funds for a long-term renovation of its headquarters. The building housed foundation staff and also prov…
Toxicology research and training grant procedures approved
A private foundation proposed grants for toxicology research and for health workers to attend seminars, conferences, and training related to poison control. Nurses, physicians, public-health workers, …
Artist scholarship and educational grant procedures were approved
A private foundation proposed scholarship and educational grant programs for working artists. Scholarships would support undergraduate or graduate study, use objective and nondiscriminatory criteria, …
Employer-related scholarship procedures were approved
A private foundation proposed scholarships for local residents attending vocational, undergraduate, or graduate programs, with preferences for current or retired employees of a food distributor and th…
Renewable county scholarship procedures were approved
A private foundation proposed need- and achievement-based scholarships for students from specified counties attending four-year colleges or technical schools. Awards would be paid directly to the scho…
Scholarship and educational grant procedures were approved
A private foundation proposed scholarships for higher education and educational grants to help individuals improve career skills in nursing, medicine, health services, aviation, and related fields. Ap…
Aviation scholarship procedures were approved
A private foundation proposed four scholarship and grant programs for aviation, aeronautics, aircraft mechanics, engineering, and other STEM education. The programs would support undergraduate and gra…
Scholarship and educational-grant procedures were approved
A private foundation proposed scholarships and educational grants for people with financial need, with an emphasis on historically marginalized communities. Scholarship recipients would attend educati…
Agriculture scholarships and youth camp grants were approved
A private foundation proposed scholarships for undergraduate agriculture, science, and technology studies and educational grants for young people to attend qualifying camps. Scholarship applicants wou…
Environmental leadership and student project grants were approved
A private foundation proposed two educational grant programs supporting environmental conservation and sustainability. One was a year-long fellowship for young environmental leaders, with awards based…
Youth-facility renovation set-aside approved
A charitable trust serving orphaned and other destitute children requested a 2022 set-aside to renovate or construct a facility for sports, arts, creative media, music, dance, emerging technology, and…
Museum-gallery renovation set-aside approved
A small private operating foundation requested a multi-year set-aside to research, redesign, and renovate a museum's main exhibit and gallery spaces, which had not been significantly renovated since o…
Scholarship procedures for future litigators approved
A private foundation proposed two annual, nonrenewable scholarships intended to diversify the pipeline of future litigators: one for an entering law student and one for a college-bound high school stu…
Employee-dependent scholarship procedures approved
A private foundation proposed annual, nonrenewable scholarships for dependents of a company's full-time employees attending two- or four-year colleges, universities, or vocational schools. An independ…
Employer-related scholarship procedures receive advance approval
A private foundation asked the IRS to approve an employer-related scholarship program for children of an employer's workers. Applicants must satisfy employment, enrollment, academic, and prior-award r…
Charitable trust may set aside income while beneficiary litigation continues
A nonexempt charitable trust held testamentary income for a hospital that had historically been exempt under section 501(c)(3). After the hospital system sold its operating assets, competing successor…
Scholarship program for low-income students receives advance approval
A private foundation proposed scholarships for graduating high school seniors from identified low-income communities. Eligible students must attend qualifying in-state colleges or technical schools fu…
Special-needs student and teacher grant procedures receive approval
A private foundation proposed two educational grant programs tied to special education. One will help students with disabilities obtain specialized educational or therapeutic services at a named schoo…
Private foundation scholarship procedures approved
A private foundation proposed annual scholarships for qualifying high school graduates who planned to attend four-year colleges or universities in the United States. Applicants would submit academic r…
Need-based college scholarship procedures approved
A private foundation proposed nonrenewable scholarships for full-time students in four-year college programs who met location, citizenship or residency, ancestry, and minimum-grade requirements. Appli…
Employer-related scholarship procedures received advance approval
A private foundation proposed a renewable scholarship program for children of an employer's owner-operators, employees, and contractors. An independent committee would evaluate academic involvement, f…
Music scholarship procedures approved
A private foundation asked the IRS to approve a scholarship program for high school seniors who demonstrate talent as vocal or instrumental performers in a specified type of music. Applicants must be …
STEM scholarships for high school athletes approved
A private foundation proposed scholarships for high school athletes in its operating area who planned to pursue postsecondary education in a science, technology, engineering, or mathematics field. Eli…
Scientific conference presentation grants approved
A private foundation proposed travel grants for graduate students, postdoctoral fellows, and faculty members presenting research in a specified field at scientific conferences. Awards had separate cap…
Four-year fellowship procedures approved
A private foundation proposed a four-year fellowship for local high school graduates and GED recipients who attend a four-year university and want work experience in a city's business community. The f…
Campus construction and equipment set-aside approved
A tax-exempt private foundation asked the IRS to approve a set-aside under section 4942(g)(2). The foundation planned to reserve a redacted amount for construction projects and equipment purchases sup…
Teacher-renewal fellowship grant procedures approved
A private foundation proposed a fellowship program to address a school district's teacher shortage by supporting educators' renewal projects. Eligible applicants had to be experienced public-school te…
Litigation-related contingent set-asides approved
A testamentary private foundation trust was required to distribute income to a charitable recipient. After that recipient sold its assets and stopped regular operations, state-law proceedings addresse…
Employer-related scholarship procedures approved
A private foundation proposed a scholarship program for children of employees of related organizations. An independent organization and selection committee would choose recipients using academic perfo…
Expanded professional fellowship procedures approved
A private foundation operated a two-phase educational program designed to prepare students for professional service in a specified community. It proposed expanding the graduate fellowship phase to app…
Law student scholarship procedures approved
A private foundation proposed scholarships for entering and current law students interested in serving an identified community. Applicants would be evaluated on community service, leadership, financia…
Theatre restoration set-aside approved
A private foundation proposed setting aside a matching grant for the second phase of a charitable organization's theatre restoration project. The grant agreement required the recipient to raise matchi…
Historic property restoration set-aside approved
A private foundation proposed setting aside a matching grant for restoration of a historic property owned by a community foundation and supported through a fiscal sponsorship fund. The agreement requi…
Affordable senior housing set-aside approved
A private foundation sought approval to set aside funds for construction of an apartment building that would provide affordable housing to low-income older adults. The foundation already housed indepe…
Art educator grant procedures approved
A private foundation proposed grants for K-12 art educators to attend professional development events in Los Angeles and create art projects about overlooked historical figures. Applicants would be ev…
Need-based scholarship procedures approved
A private foundation proposed nonrenewable scholarships for students in a specified location who lacked the financial means to earn a degree. Applicants would be evaluated using academic records, fina…
International professional fellowship procedures approved
A private foundation proposed a fellowship program that would place experienced professionals with public institutions and nonprofit organizations in another country. Fellows would receive living stip…
Scholarship and talent-development grant procedures approved
A private foundation proposed two programs for people with financial need. One would pay tuition and related educational costs for students of any age attending accredited schools. The other would hel…
Social justice scholarship procedures approved
A private foundation proposed a scholarship program for full-time students pursuing degrees related to law, social justice, criminal justice, and similar fields. A selection committee would consider c…
Foundation's educational research grant procedures approved
A private foundation proposed grants to individuals who would study issues affecting young people in a community and produce reports recommending possible solutions. The foundation planned public outr…
Art lending collection treated as direct charitable use
A private foundation supported the arts through grants and planned to lend a donated and purchased collection of paintings and sculptures to public museums, galleries, schools, universities, and simil…
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.