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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Foundation receives five more years to sell excess business holdings
A private foundation received a 50 percent membership interest in a health care holding company from a disqualified person. The unusually large gift created excess business holdings, and the company h…
Filmmaker fellowship grant procedures approved
A private foundation proposed a one-year fellowship program for filmmakers from a redacted ethnic community. The grants would support culturally significant documentary and narrative films, with recip…
Science fellowship and travel grant procedures approved
A private foundation proposed fellowship and travel awards for early-career scientists. Fellowship candidates would be ranked by a selection committee, with the board making final selections and host …
Employee-dependent scholarship procedures approved
A private foundation proposed scholarships for dependent children of qualifying full-time employees of a company. An independent tax-exempt organization would manage the program, and an independent co…
Student-athlete scholarship procedures approved
A private foundation proposed at least two one-time annual scholarships for graduating student athletes at a specified high school, one boy and one girl. Applicants would need college acceptance and a…
Performing-artist grant procedures approved
A private foundation asked the IRS to approve procedures for grants supporting mid-career performing artists. The program would use nominations, eligibility screening, expert review, interviews, and f…
IRS approves a private foundation's set-aside of funds to build a regional performing arts center
Private foundations must pay out a minimum amount each year, but they can "set aside" money for a big future project and still have it count toward that payout requirement, as long as the IRS approves…
IRS approves a private foundation's grant procedures for young professional equestrians
A private foundation asked the IRS to approve, in advance, how it plans to award grants to individual athletes. Private foundations normally owe an excise tax on grants to individuals for study or sim…
IRS approves a private foundation's grant procedures for teacher-retention educational grants
A private foundation asked the IRS to approve, in advance, the way it plans to hand out educational grants to individuals. Private foundations normally owe an excise tax on grants to individuals for s…
IRS approves a poetry foundation's travel-expense grants for prize winners under § 4945(g)(3)
A private foundation, an independent literary organization devoted to poetry, asked the IRS to pre-approve the procedures for a grant program that pays the travel, meal, and lodging costs of people wh…
IRS approves a private foundation's scholarship and educational-grant procedures under § 4945(g)
A private foundation asked the IRS to pre-approve the procedures it will use to give money to individuals: scholarships for study at educational institutions, and grants for travel, study, or specific…
IRS pre-approves a foundation's college-mentoring scholarship and educational-grant procedures under § 4945(g)(1) and (g)(3)
A private foundation asked the IRS to pre-approve two kinds of individual grant programs: scholarships (under section 4945(g)(1)) and educational grants (under section 4945(g)(3)). When a private foun…
IRS pre-approves a foundation's scholarship and educational-grant procedures under § 4945(g)(1) and (g)(3)
A private foundation asked the IRS to pre-approve two kinds of individual grant programs: scholarships and fellowships (under section 4945(g)(1)) and broader educational grants (under section 4945(g)(…
IRS pre-approves a company foundation's employer-related scholarship program for employees' children under § 4945(g)(1)
A private foundation tied to a company asked the IRS to pre-approve its procedures for awarding scholarships to the children of the company's employees. This advance approval matters because a private…
IRS pre-approves a foundation's grant program for high school teachers under § 4945(g)(3)
A private foundation asked the IRS to approve, in advance, procedures for a grant program (not tuition scholarships) that funds high school teachers' own projects. Under IRC § 4945(g)(3), a foundation…
IRS pre-approves a private foundation's need-based scholarship procedures under § 4945(g)(1)
A private foundation asked the IRS to approve, in advance, its scholarship award procedures. Private foundations owe an excise tax on grants to individuals for study unless the IRS approves the proced…
IRS pre-approves a private foundation's scholarship procedures for healthcare-field students under § 4945(g)(1)
A private foundation asked the IRS to approve, in advance, how it awards scholarships. Private foundations owe an excise tax when they give money to individuals for study unless the IRS blesses the gr…
IRS grants a private foundation more time to spend a set-aside for a construction project delayed by COVID-19
A private foundation had earlier been approved to "set aside" money for a specific construction project, a device that lets a foundation count committed-but-unspent funds toward its required annual pa…
IRS pre-approves a private foundation's high school scholarship procedures under § 4945(g)(1)
A private foundation asked the IRS to approve, in advance, how it selects and awards scholarships. Private foundations normally owe an excise tax when they hand money to an individual for study, but I…
IRS approves a foundation's grant procedures for a religious teen learning program run with a university
A private foundation asked the IRS for advance approval of its educational-grant procedures under section 4945(g)(3), the category for grants that let a recipient achieve a specific objective or impro…
IRS approves a foundation's grant procedures for goal-oriented individuals to achieve a specific objective or improve a skill
A private foundation asked the IRS for advance approval of its educational-grant procedures under section 4945(g)(3), the category for grants that let a recipient achieve a specific objective or impro…
IRS approves a foundation's scholarship procedures for underprivileged children's primary and secondary education
A private foundation asked the IRS for advance approval of its scholarship procedures under section 4945(g)(1). Without this approval, a private foundation's grants to individuals for study can be "ta…
IRS approves a foundation's three fellowship programs for improving youth mental health
A private foundation asked the IRS for advance approval of its educational-grant procedures under section 4945(g)(3), the category for grants that let a recipient achieve a specific objective or impro…
IRS approves a foundation's scholarship procedures for low-income students in a partner program
A private foundation asked the IRS for advance approval of its scholarship procedures under section 4945(g)(1). Without this approval, a private foundation's grants to individuals for study can be "ta…
IRS approves a private foundation's scholarship procedures for children of an organization's members
A private foundation asked the IRS for advance approval of the procedures it uses to award scholarships, as section 4945(g)(1) requires. Without this approval, grants a private foundation makes to ind…
IRS pre-approves a foundation's fellowship grants for educators' professional development
A private foundation asked the IRS to approve, in advance, the procedures for grants it awards to educators for professional development and leadership. This approval matters because grants a private …
IRS pre-approves a foundation's graduate scholarship program in a targeted field
A private foundation asked the IRS to approve, in advance, the procedures for a scholarship program that funds students pursuing graduate or doctoral degrees in a particular field. This approval matte…
IRS grants a 36-month extension to pay out a foundation's set-aside for an arts facility delayed by COVID-19
A private foundation had earlier received IRS approval for a "set-aside," a way for a foundation to earmark money for a specific long-term project and count it toward the annual payout the tax law req…
IRS pre-approves a memorial scholarship for graduating high school seniors
A private foundation asked the IRS to approve, in advance, the procedures for a scholarship it runs in memory of a named individual. This approval matters because grants a private foundation makes to …
IRS pre-approves a foundation's grant program for low-income amateur athletes
A private foundation asked the IRS to approve, in advance, the procedures it will use to award grants to individual amateur athletes. This approval matters because grants a private foundation makes to…
IRS pre-approves a firm foundation's diversity scholarship for future CPAs
A private foundation asked the IRS to approve, in advance, the way it plans to award scholarships. This step matters because grants a private foundation makes to individuals for study are normally "ta…
IRS pre-approves a foundation's scholarship program for students facing socio-economic barriers
A private foundation asked the IRS to approve, in advance, the way it plans to award college scholarships. This step matters because grants a private foundation makes to individuals for study are norm…
IRS pre-approves a foundation's bank-administered college scholarship program
A private foundation asked the IRS to approve, in advance, the way it plans to award college scholarships. This step matters because grants a private foundation makes to individuals for study are norm…
IRS pre-approves a foundation's grants covering conference travel for those who cannot afford it
A private foundation asked the IRS to approve, in advance, how it will award grants that cover travel and lodging so people who cannot afford it can attend the foundation's financial-education confere…
IRS pre-approves a foundation's fellowship grant procedures for financial-education scholars
A private foundation asked the IRS to approve, in advance, the way it plans to award educational grants. This step matters because grants a private foundation makes to individuals for study or similar…
IRS approves a private foundation's scholarship procedures under section 4945(g)(1)
A private foundation asked the IRS to approve in advance its procedures for awarding scholarships. Under section 4945, a private foundation's grants to individuals for study count as taxable expenditu…
IRS approves a private foundation's educational-grant procedures under section 4945(g)(3)
A private foundation asked the IRS to approve in advance its procedures for making educational grants to individuals. Private foundations normally owe an excise tax under section 4945 on grants to ind…
Private foundation gets five more years to shed excess business holdings in a complex family company
A private foundation, funded by a trust that a now-deceased business owner set up, received a large block of stock (about 12 percent) in a closely held family holding company as part of a bequest. Pri…
Private foundation could transfer all assets to a commonly controlled foundation
Two private foundations controlled by the same trustees planned to consolidate by having one foundation transfer all of its assets to the other without consideration. The IRS ruled that the transfer q…
Foundation could transfer all assets and terminate without excise tax
A private foundation planned to consolidate with another foundation controlled by the same trustees by transferring all of its assets without receiving consideration. The IRS ruled that the transfer w…
Need-based scholarship procedures received advance approval
A private foundation proposed need-based scholarships for students from underserved communities attending college, university, community college, or a post-high-school trade school. Eligibility consid…
Emergency scholarship grant procedures approved
A private foundation requested advance approval for a scholarship program serving current college, graduate, and other post-secondary students facing recent unexpected financial difficulties. Grants c…
Employer-related scholarship procedures approved
A private foundation proposed scholarships for dependent children of employees in several geographic employee groups. An independent third-party administrator would evaluate academic performance, lead…
Alumni educational-project grant procedures approved
A private foundation proposed one-time grants to alumni of three schools for innovative educational projects benefiting children, families, and communities. Applicants would submit a project descripti…
IRS pre-approves a foundation's archery-tournament scholarship procedures under section 4945(g)
A private foundation asked the IRS to bless the way it hands out scholarships before it starts writing checks. This matters because section 4945 taxes a private foundation on grants it makes to indivi…
IRS pre-approves a foundation's scholarship procedures for local undergraduate students under section 4945(g)
A private foundation asked the IRS to approve, in advance, how it will award scholarships. This approval matters because section 4945 taxes a private foundation on grants it makes to individuals for s…
Scholarship and special-education grant procedures approved
A private foundation requested advance approval for scholarships under section 4945(g)(1) and educational grants under section 4945(g)(3). Its program would support undergraduate and graduate study an…
Entrepreneurship scholarship procedures approved
A private foundation requested advance approval for a scholarship and summer internship program for high school juniors and seniors interested in entrepreneurship. Participants would work with local b…
Employer-related scholarship procedures approved
A family foundation requested advance approval for scholarships publicized through a related employer and available to children or stepchildren of qualifying current or deceased employees. An independ…
Scholarship procedures approved for low-income students
A private foundation sought advance approval for a scholarship program serving low-income current or former residents of a state, with a preference for people connected to one county. Awards would be …
Advance approval of a foundation's fellowship-grant procedures for early-career therapists under section 4945(g)(3)
A private foundation asked the IRS to pre-approve the procedures it will use to award educational fellowship grants to individuals. Advance approval matters because a private foundation that pays a gr…
IRS approves a private foundation's set-aside to fund a multi-year drug-development and cultural-facility project
A private foundation asked the IRS to approve a "set-aside" under section 4942(g)(2). Private foundations must pay out a minimum amount each year for charitable purposes, and a set-aside lets a founda…
202313012: IRS approves need-based college scholarship procedures
A private foundation proposed scholarships for financially needy graduating high school students attending accredited postsecondary institutions in a specified state. The program would prioritize stud…
202313011: IRS approves applied-science and engineering scholarship procedures
A private foundation proposed renewable scholarships for students pursuing engineering, applied sciences, or related fields in a specified area. A selection committee appointed by the board would eval…
202311009: IRS approves scholarship procedures for student athletes
A private foundation requested advance approval for a scholarship program that would help student athletes pay for textbooks and study materials at colleges, universities, and technical or vocational …
202311008: IRS approves employer-related scholarship procedures
A private foundation sought advance approval for an employer-related scholarship program benefiting children or relatives of employees of a corporation. An independent nonprofit would run the competit…
Advance approval of a foundation's leadership-development fellowship procedures under section 4945(g)(3)
A private foundation asked the IRS to pre-approve how it awards educational grants, which private foundations must do under section 4945(g) to avoid an excise tax on grants to individuals. The foundat…
Advance approval of a fire department foundation's memorial scholarship procedures under section 4945(g)
A private foundation asked the IRS to pre-approve how it awards scholarships, which private foundations must do under section 4945(g) to avoid an excise tax on grants to individuals. The foundation ru…
Advance approval of a private foundation's STEM scholarship procedures under section 4945(g)
A private foundation asked the IRS to pre-approve the way it awards scholarships. Private foundations owe an excise tax on grants to individuals for study unless the IRS approves the grant-making proc…
IRS approves a private foundation's set-aside to fund multi-year construction of a public cultural and educational center
A private foundation asked the IRS to approve a "set-aside." Private foundations normally must pay out a minimum amount for charitable purposes each year, but section 4942(g)(2) lets a foundation inst…
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.