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's scholarship-award procedures approved in advance, so the grants aren't taxable expenditures
A private foundation asked the IRS to pre-approve the way it runs its scholarship program. This matters because when a private foundation gives money to individuals for study, that grant is normally a…
IRS grants advance approval of a foundation's teacher-fellowship grant procedures under 4945(g)(3)
A private foundation asked the IRS to bless the procedures it uses to award educational grants to individuals. This approval matters because section 4945 hits a private foundation with an excise tax o…
IRS approves a private foundation's set-aside to fund construction of a youth 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…
The IRS approves a foundation's set of scholarship programs for at-risk youth, so the grants are not taxable expenditures
A private foundation asked the IRS to approve, in advance, the procedures for several scholarship programs it runs to help at-risk and disadvantaged high school graduates go on to trade school or coll…
The IRS approves a private foundation's scholarship procedures, so the awards are not taxable expenditures
A private foundation asked the IRS to bless the way it runs a college scholarship program before it starts handing out money. This advance approval matters because section 4945 hits private foundation…
IRS pre-approves a private foundation's scholarship and teacher-grant procedures
A private foundation asked the IRS to approve, in advance, how it will award two kinds of grants to individuals: graduate fellowships for students studying teaching and education (under Section 4945(g…
Private foundation's renewable scholarship procedures received advance approval
A private foundation proposed renewable scholarships for first-time undergraduate or vocational students from specified counties. Applicants needed at least a 2.5 grade point average, and selection co…
Foundation received approval to set aside funds for artist-residency renovations
A private foundation provides undisturbed residency space for writers and visual artists. It sought to set aside funds for extensive renovations that would keep its residency property open year-round …
Foundation received five more years to sell inherited business holdings
A private foundation inherited minority interests in a corporation and an LLC, creating excess business holdings under section 4943. Transfer restrictions, regulatory approval requirements, adversaria…
Foundation's scholarship, prize, fellowship, and educational grants approved
A private foundation that promotes global citizenship asked to expand the ways it funds individuals. It proposed scholarships for students pursuing relevant studies, achievement awards for members of …
Employer-related scholarships expanded to employees' children abroad
A private foundation had prior approval for an employer-related scholarship program and asked to expand it to dependent children of employees at affiliated companies outside the United States. Interna…
Foundation received more time to build its scholarship headquarters
A private foundation previously received approval to set aside funds for an academy that would serve as headquarters and a workshop site for its scholarship program. The COVID-19 pandemic changed the …
IRS approves a renewable college scholarship program
A private foundation asked the IRS to approve its procedures for renewable scholarships for high school seniors, graduates, and GED recipients entering undergraduate or vocational study. Applicants ha…
IRS approves a litigation-related contingent set-aside
A private foundation was subject to a court order requiring a fiduciary to hold distributions otherwise payable to one beneficiary while litigation was pending. The funds had to remain invested with t…
IRS approves a community scholarship program
A private foundation created a nonrenewable scholarship program honoring its founder and serving members of a large religious community, their children, and participants in the community's youth and r…
IRS approves expanded international employee scholarships
A private foundation asked to expand an already approved employer-related scholarship program to children of employees of affiliated companies outside the United States. International awards would gen…
IRS approves employer-related community scholarship procedures
A private foundation asked the IRS to approve an employer-related scholarship program for students in its community. Employees and their dependents could apply after six months of employment, and othe…
IRS approves a foundation's scholarship procedures for local students under section 4945(g)(1)
A private foundation asked the IRS to approve, in advance, how it awards scholarships. Private foundations owe an excise tax on grants to individuals for study unless the IRS pre-approves the award pr…
IRS approves a foundation's educational-grant procedures for faith-based social entrepreneurs under section 4945(g)(3)
A private foundation asked the IRS to approve, in advance, how it awards educational grants. Private foundations owe an excise tax on grants to individuals unless the IRS pre-approves the award proced…
IRS approves a foundation's scholarship procedures for local high school and vocational students under section 4945(g)(1)
A private foundation asked the IRS to approve, in advance, how it awards scholarships. Private foundations owe an excise tax on grants to individuals for study unless the IRS pre-approves the award pr…
IRS approves a private foundation's scholarship procedures under section 4945(g)(1)
A private foundation asked the IRS to approve, in advance, the way it picks students to receive scholarships. Private foundations owe an excise tax on "taxable expenditures," and a grant to an individ…
IRS approves a foundation's scholarship procedures for youth-development program members under section 4945(g)(1)
A private foundation asked the IRS to bless, in advance, how it awards scholarships to members of a youth-development and agricultural-education program pursuing higher education. Private foundations …
IRS approves a media-affiliated foundation's scholarship and educational-grant procedures under sections 4945(g)(1) and (g)(3)
A private foundation affiliated with a large international media company asked the IRS to approve, in advance, two sets of award procedures: scholarships under IRC section 4945(g)(1) and other educati…
Scholarship procedures for graduating seniors approved
A private foundation asked the IRS to pre-approve the procedures it uses to award college scholarships. Under section 4945, a grant a private foundation makes to an individual for study is a "taxable …
Dissertation-research grant procedures approved
A private foundation asked the IRS to pre-approve the procedures for a program that funds PhD dissertation research. Under section 4945, a private foundation's grants to individuals for study are "tax…
Need-based scholarship procedures approved
A private foundation asked the IRS to pre-approve its need-based scholarship procedures. Under section 4945, a private foundation's grants to individuals for study are "taxable expenditures" that trig…
Theological doctoral scholarship procedures approved
A private foundation asked the IRS to pre-approve the procedures for a scholarship program that funds doctoral study in theology. Under section 4945, a private foundation's grants to individuals for s…
Business-major scholarship procedures approved
A private foundation asked the IRS to pre-approve the procedures for a scholarship program aimed at low-income, high-achieving students. Under section 4945, a private foundation's grants to individual…
College-readiness scholarship procedures approved
A private foundation asked the IRS to pre-approve its scholarship procedures. Under section 4945, a private foundation's grants to individuals for study are "taxable expenditures" that trigger an exci…
At-risk youth mentorship scholarship procedures approved
A private foundation asked the IRS to pre-approve the procedures for a scholarship program aimed at at-risk youth. Under section 4945, a private foundation's grants to individuals for study are "taxab…
Graduate-school scholarship procedures approved
A private foundation asked the IRS to pre-approve the procedures for a graduate-school scholarship program. Under section 4945, a private foundation's grants to individuals for study are "taxable expe…
Research grant procedures approved under 4945(g)(3)
A private foundation asked the IRS to pre-approve the procedures for making research grants to individuals. Under section 4945, a private foundation's grants to individuals for study or research are "…
International scholarship procedures approved
A private foundation asked the IRS to pre-approve the procedures for a scholarship program serving students from developing countries. Under section 4945, a private foundation's grants to individuals …
Need-based state scholarship procedures approved
A private foundation asked the IRS to pre-approve its scholarship procedures. Under section 4945, a private foundation's grants to individuals for study are "taxable expenditures" that trigger an exci…
IRS approves a company foundation's employer-related scholarship procedures under 4945(g)(1)
A private foundation tied to a company asked the IRS to pre-approve the way it runs an employer-related scholarship program. The program pays for the college education of the children of the company's…
IRS approves a foundation's educational grant procedures for a BIPOC dance-artist support program under 4945(g)(3)
Private foundations normally owe an excise tax when they hand grant money to individuals for study or travel, unless the IRS approves the foundation's grant-making procedures in advance. Here a founda…
IRS approves a foundation's grant procedures for a fellowship on faith and gender equality under 4945(g)(3)
A private foundation normally owes an excise tax when it gives grant money to individuals for study or similar purposes, unless the IRS has approved its grant procedures in advance. This foundation so…
Closed-year interest remains in the balance for open-year self-dealing tax
A private foundation made a self-dealing loan to a disqualified person, and unpaid interest was added to the loan balance each year. By the time of examination, the assessment period had expired for t…
Educational-facility construction set-aside approved
A private foundation requested approval to set aside an amount for construction of an educational facility with classrooms and research space. COVID-19 disruptions made project scheduling uncertain, c…
IRS approves a private foundation's high school scholarship procedures in advance, so the grants aren't taxable expenditures
A private foundation asked the IRS to approve, in advance, the procedures it uses to award college scholarships to graduating seniors of two high schools. This approval matters because section 4945 ta…
IRS approves a foundation's scholarship procedures for professional-development grants to under-represented communities
A private foundation asked the IRS to pre-approve the way it runs a scholarship program, and the IRS said yes. This advance approval matters because a private foundation normally owes an excise tax wh…
IRS grants advance approval of a private foundation's scholarship and educational grant procedures
A private foundation asked the IRS to approve, in advance, how it will award scholarships and related educational grants. This approval matters because section 4945 taxes a private foundation's "taxab…
IRS approves a foundation's set-aside for a historic decorative-arts restoration matching grant
A private foundation asked the IRS to approve a "set-aside," which lets it earmark money now for a specific project and still count it toward the minimum it must distribute each year, as long as it pa…
IRS approves a foundation's set-aside for a matching grant to a community fund's historic restoration
A private foundation asked the IRS to approve a "set-aside," which lets it earmark money now for a specific project and still count it toward its required annual distributions, as long as it pays with…
IRS approves a foundation's set-aside for phase three of a historic building restoration
A private foundation asked the IRS to approve a "set-aside," which lets it earmark money now for a specific project and still count it toward the minimum amount it must distribute each year, as long a…
IRS approves a private foundation's set-aside for a historic restoration matching grant
A private foundation asked the IRS for permission to "set aside" money for a specific project instead of paying it out right away. Private foundations must distribute a minimum amount each year, and n…
High school scholarship procedures approved
A private foundation asked the IRS to approve, in advance, the way it awards a scholarship, so that the payments would not count as "taxable expenditures" that trigger excise tax under section 4945. T…
A private foundation gets 60 days to make late elections its preparer forgot, treating grants from another foundation as distributions out of corpus
A private foundation regularly received grants from another private foundation under agreements that required it to pass the money along and to make a specific tax election each year. That election, u…
Third companion ruling on a family private foundation moving at least 80% of its assets, including a large bequest, to two related foundations tax-free
This is the third of three companion letters (control numbers PLR-116647-21, PLR-116648-21, and PLR-116649-21) issued the same day on a single transaction. A family-run grant-making private foundation…
Companion ruling letting a family private foundation move at least 80% of its assets, including a large bequest, to two related foundations without termination or excise taxes
This ruling is a companion to PLR 202231006, issued the same day on the same transaction (the two letters carry consecutive control numbers, PLR-116648-21 and PLR-116647-21). A family-run grant-making…
A family private foundation can move at least 80% of its assets, including a large bequest, to two related family foundations without termination or excise taxes
A family-run grant-making private foundation expected to receive a large bequest from a deceased donor. It planned to transfer at least 80 percent of its assets, including that bequest, to two other p…
Family foundation cleared to move most of its assets, including a large bequest, to two related foundations without triggering private-foundation excise taxes
A family controls three private foundations: an existing family foundation, a company foundation, and a newly created foundation. The family foundation expects a large bequest from a donor who died se…
IRS pre-approves a foundation's grant program for illustrators and picture-book writers
A private foundation asked the IRS to approve, in advance, the procedures it uses to award educational grants to individuals. This step matters because a private foundation's grants to individuals for…
IRS pre-approves a foundation's scholarship and issue-analysis grant programs
A private foundation asked the IRS to approve, in advance, two sets of procedures: one for awarding scholarships under section 4945(g)(1) and one for awarding educational grants to individuals under s…
IRS approves a private foundation's scholarship procedures
A private foundation asked the IRS to approve, in advance, the procedures for a scholarship program it planned to run to help students afford the schools of their choice. To qualify, a student had to …
IRS approves a union-affiliated organization's scholarship procedures for children of local-union members
A private foundation associated with a labor organization asked the IRS to approve, in advance, how it will award college scholarships. Without advance approval, a private foundation's grants to indiv…
IRS approves a foundation's need-based scholarship procedures for students at Christian grade and high schools
A private foundation asked the IRS to approve, in advance, how it will award need-based scholarships to children attending private Christian grade schools and high schools. Without advance approval, a…
IRS approves scholarship procedures for underrepresented, first-generation undergraduates
A private foundation asked the IRS to approve, in advance, how it will award scholarships aimed at underrepresented students. Without advance approval, a private foundation's grants to individuals for…
IRS approves a foundation's scholarship procedures for high school students bound for four-year colleges
A private foundation asked the IRS to approve, in advance, how it will award college scholarships to high school students, primarily for four-year colleges. Without advance approval, a private foundat…
IRS approves a foundation's grants funding flights for healthcare professionals' medical mission trips
A private foundation asked the IRS to approve, in advance, how it will award grants to individuals. Without advance approval, a private foundation's grants to individuals can trigger an excise tax und…
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.