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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IRS approves scholarship procedures funding low-income students at high-graduation-rate colleges
A private foundation asked the IRS to approve, in advance, how it will award college scholarships. Without advance approval, a private foundation's grants to individuals for study can trigger an excis…
IRS approves a foundation's scholarship program for graduating seniors whose families belong to a sponsoring organization
A private foundation asked the IRS to bless the way it hands out college scholarships. Private foundations owe an excise tax on "taxable expenditures," and grants to individuals for study count unless…
IRS approves a foundation's research-grant program to document endangered oral literature and ecological knowledge
A private foundation runs a research-grant program that funds anthropologists, linguists, and local researchers to document and preserve endangered oral literature and traditional ecological knowledge…
IRS approves a company-linked foundation's scholarships for students entering the skilled trades
A private foundation funded by a company (the company's owners serve as the foundation's officers) asked the IRS to approve its scholarship procedures under IRC § 4945(g)(1). The program awards schola…
IRS approves a private foundation's non-profit-leadership fellowship procedures under section 4945(g)(3)
A private foundation asked the IRS to approve, in advance, how it will run a fellowship program that trains and funds emerging non-profit leaders working on social change. This advance approval matter…
IRS approves a private foundation's college scholarship program under section 4945(g)(1)
A private foundation asked the IRS to approve, in advance, the way it hands out college scholarships. This approval matters because a private foundation that makes grants to individuals for study norm…
IRS pre-approves a private foundation's artist- and scholar-residency grant program
A private foundation asked the IRS to approve, in advance, the procedures it uses to award grants to individuals. This step matters because a private foundation's grants to individuals for travel or s…
IRS grants advance approval of a foundation's scholarship program for parents and caregivers pursuing post-secondary education
A private foundation runs a scholarship program to help parents and caregivers in a particular area access post-secondary education (2- to 4-year colleges, trade, vocational, and certificate programs)…
IRS grants advance approval of a foundation's first-year college scholarship program for local high school seniors
A private foundation runs a scholarship program helping graduating high school seniors from a specific area with their first-year college expenses. Grants to individuals can trigger an excise tax on a…
IRS grants advance approval of a foundation's trade-school scholarship program for low-income high school seniors
A private foundation runs a scholarship program for graduating high school seniors from low-income households who want to train for a trade rather than attend a traditional college. Grants to individu…
IRS grants advance approval of a foundation's international scholarship program with a youth-mentoring requirement
A private foundation runs a scholarship program funding college, university, and vocational (TVET) study for qualifying students tied to a particular geographic region, with a distinctive "give back" …
IRS grants advance approval of a foundation's grant procedures funding vocal study for program alumni
A private foundation makes grants to individual singers who are alumni of its program, funding summer study and young-artist programs (tuition, housing, travel, or private study with a voice teacher o…
IRS grants advance approval of a foundation's scholarship and educational grant procedures
A private foundation runs two programs that pay money to individual students: a scholarship program for graduating high school students, and a broader educational grant program funding things like mus…
IRS grants advance approval of a foundation's procedures for scholarship grants supporting middle and high school students
A private foundation asked the IRS to approve, in advance, how it will award grants to individual students. The program supports middle and high school students by preparing them for post-secondary ed…
IRS grants advance approval of a private foundation's procedures for awarding medical research grants
A private foundation that wants to make grants to individuals for study or research normally risks an excise tax on those grants unless the IRS approves its grant-making procedures in advance. This fo…
Advance approval of a private foundation's grant procedures for an opera-singer training program
A private foundation runs a month-long training and coaching program for young opera singers, providing housing, meals, and coaching from opera-house professionals as they transition from conservatory…
IRS grants a private foundation advance approval of its scholarship procedures for vocational-training students (§ 4945(g)(1))
A private foundation asked the IRS to approve, in advance, the way it will run a scholarship program. This step matters because IRC § 4945 taxes a private foundation's "taxable expenditures," and a gr…
IRS approves a foundation's post-doctoral fellowship grant procedures under § 4945(g)(3)
A private foundation asked the IRS to approve, in advance, the procedures for a post-doctoral research fellowship program it will run. Private foundations normally owe an excise tax on grants to indiv…
IRS approves a foundation's educational grant procedures under § 4945(g)(3)
A private foundation asked the IRS to approve, in advance, the procedures for an educational grant program it will run. Private foundations normally owe an excise tax on grants to individuals for stud…
IRS approves a foundation's merit-based scholarship procedures under § 4945(g)(1)
A private foundation asked the IRS to approve, in advance, the procedures it will use to award scholarships. Private foundations normally owe an excise tax on grants to individuals for study, but Sect…
IRS approves a foundation's employer-related scholarship procedures
A private foundation asked the IRS to approve, in advance, the procedures for an employer-related scholarship program it will run. Private foundations normally owe an excise tax on grants to individua…
IRS approves a foundation's procedures for sabbatical and summer research grants to scholars
A private foundation asked the IRS to approve, in advance, how it will award research grants to individuals. Private foundations normally owe an excise tax on grants to individuals for study or simila…
IRS approves a private foundation's contingent set-aside for grant funds frozen by a court order
A private foundation must pay out a minimum amount each year for charitable purposes or face an excise tax on its undistributed income under Section 4942. Here a court order arising from litigation di…
IRS approves a private foundation's contingent set-aside for funds a court order barred it from distributing
A private foundation must pay out a minimum amount each year or face an excise tax on the money it holds back (Section 4942). Here the foundation could not make some of its required distributions beca…
IRS approves a foundation's grant procedures for funding tenured professors' interdisciplinary research
A private foundation asked the IRS to approve, in advance, the way it plans to award grants to individuals. Private foundations normally owe an excise tax on grants to individuals for study or similar…
IRS approves a foundation's grant procedures for a game-design stipend program
A private foundation asked the IRS to approve, in advance, the way it plans to award grants to individuals. Private foundations normally owe an excise tax on grants to individuals for study or similar…
IRS approves a foundation's scholarship procedures for students at historically black colleges
A private foundation asked the IRS to approve, in advance, the way it plans to award scholarships. Private foundations normally owe an excise tax on grants to individuals for study, but Section 4945(g…
IRS approves a private foundation's employer-related scholarship procedures under section 4945(g)(1)
A private foundation asked the IRS to approve, in advance, the way it runs an employer-related scholarship program, and the IRS approved it. This advance approval matters because a private foundation …
Advance approval of a private foundation's procedures for student travel and conference stipends under section 4945(g)
A private foundation asked the IRS to approve, in advance, its procedures for a new set of educational grants: travel stipends and conference stipends for graduate fellows and undergraduate scholars a…
Scholarship program procedures approved
A private foundation asked the IRS to approve, in advance, how it will award scholarships under its program. The program provides financial help to underserved young adults in a particular area who wa…
A donated art collection and donor name recognition are not self-dealing, and the art is exempt from the foundation payout base
A private foundation is set to receive a valuable art collection from a trust created by one of its directors, along with cash to pay for curation and gallery space. That director, his son (also a dir…
Advance approval of a private foundation's creator-grant program under 4945(g)(3)
A private foundation asked the IRS to approve, in advance, the procedures for a grant program that funds individual creators (podcasters, filmmakers, writers, musicians, artists, journalists, and othe…
Private foundation gets advance approval for its scholarship, arts, and business-development grant procedures
A private foundation that hands out grants to individuals for study or similar purposes normally owes an excise tax on those payments (a "taxable expenditure") under Internal Revenue Code § 4945, unle…
IRS approves a private foundation's 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. Foundations normally owe an excise tax on grants to individuals for study, but Section 49…
IRS approves a private foundation's individual educational grant procedures under Section 4945(g)
A private foundation asked the IRS to pre-approve how it awards educational grants to individuals before it starts making them. Private foundations normally owe an excise tax on grants to individuals …
A private foundation gets advance approval to run an employer-related scholarship program without triggering excise tax
A private foundation runs a scholarship program for the children of a particular employer's workers and asked the IRS to pre-approve its award procedures. This approval matters because a private found…
A private foundation gets advance approval for its scholarship procedures, so grants to students won't be taxable expenditures
A private foundation runs a scholarship program that pays tuition and a living stipend for under-resourced students in one city, and it asked the IRS to pre-approve how it picks recipients. This matte…
A private foundation gets advance approval for changes to both its regular and employer-related scholarship programs
A private foundation had already gotten IRS approval for two scholarship programs and wanted to make material changes to both, so it asked the IRS to re-approve its award procedures under section 4945…
IRS approves a private foundation's 5-year set-aside under section 4942(g)(2) to fund construction and renovation for programs serving orphaned and destitute children
A private foundation whose mission is to serve orphaned and destitute children asked the IRS to approve a "set-aside" under section 4942(g)(2). A set-aside lets a private foundation earmark money now,…
A private foundation's assignment of its trust remainder interest to a public charity will not create excess business holdings under section 4943
A private foundation held a residuary (remainder) interest in a testamentary trust whose assets include a large stake in a holding company that owns an operating business. The foundation assigned most…
IRS grants advance approval of a private foundation's scholarship procedures under section 4945(g) for a program tracking disadvantaged students from elementary school through college
A private foundation asked the IRS for advance approval of the procedures it will use to award scholarships. Private foundations must get this approval so their grants to individuals are not treated a…
IRS grants advance approval under section 4945(g) of a private foundation's scholarship procedures for a sponsor-based program awarding scholarships to members' children and grandchildren
A private foundation asked the IRS for advance approval of the procedures it will use to award scholarships. Private foundations need this approval so their grants to individuals are not treated as "t…
Business stock a public charity receives from a trust under a foundation's assignment will not be treated as excess business holdings under section 4943
This ruling is the companion to a related ruling issued to the private foundation on the same assignment, but here the request is made by the public charity. A private foundation held a residuary (rem…
IRS approves a private foundation's set-aside for a community facility
A private operating foundation asked the IRS to approve a set-aside for a multi-year facility construction project. The facility's detailed purpose was redacted, but the letter says it would support t…
IRS approves a set-aside for university research equipment grants
A private foundation asked the IRS to approve a multi-year set-aside for grants to U.S. universities. The grants would help selected laboratories purchase and install specialized equipment for emergin…
Foundation receives five more years to dispose of inherited company stock
A private foundation inherited a large minority stake in a complex, closely held company from its creator through a trust, leaving the foundation with excess business holdings under Section 4943. Duri…
Private foundation's need-based scholarship procedures receive advance approval
A private foundation asked the IRS to approve procedures for scholarships serving financially needy graduates of high schools in a specified county and state. The program would award approximately a r…
Foundation receives advance approval for scholarship and individual grant programs
A private foundation sought advance approval for scholarship procedures under Section 4945(g)(1) and other individual grant procedures under Section 4945(g)(3). Its scholarships would support students…
Foundation receives advance approval for scholarships and educational grants
A private foundation proposed scholarships for higher-education students who lacked sufficient financial resources and educational grants for individuals pursuing artistic, intellectual, or other skil…
Grants to an independent city-supporting organization qualify and are not taxable expenditures
A private foundation planned to fund a Type III functionally integrated supporting organization created to help a city maintain budget stability, reduce its property-tax rate, and undertake community …
IRS approves a matching-grant set-aside for historic restoration
A private foundation asked to set aside a grant for a county historical society’s restoration of a historic public structure. The foundation planned to provide roughly one-third of the project cost as…
IRS approves a private foundation's procedures for university scholarship programs
A private foundation affiliated with an exempt banking organization requested advance approval for two scholarship programs offered through several universities. Eligible applicants included employees…
IRS approves a county-based scholarship program for graduating students
A private foundation requested advance approval for a scholarship program encouraging county high school graduates, including home-schooled students, to pursue university, college, vocational, or tech…
IRS approves an employer-related scholarship program administered by an independent charity
A private foundation proposed funding an employer-related scholarship program through an independent public charity for dependent children of qualifying employees worldwide. The charity would verify e…
IRS approves grants to silent-film accompanists
A private foundation proposed grants to qualified musicians who would provide live accompaniment for public presentations of restored silent films. A committee of at least three people would select mu…
IRS approves charitable-leadership fellowship procedures
A private foundation proposed fellowships for promising leaders and innovators to pursue specific charitable objectives, with an initial focus on historically disenfranchised communities. Applicants w…
IRS approves scholarship and individual-achievement grants
A private foundation proposed two types of grants supporting a cultural shift toward equality, partnership, and a caring society. Section 4945(g)(1) scholarships would help financially needy undergrad…
IRS approves international civic-leadership fellowships
A private foundation supported a year-long fellowship placing recent college graduates with mission-oriented organizations in three countries. Fellows would work full time, receive stipends, attend tr…
IRS approves three scientific grant programs
A private foundation proposed three grant programs supporting research and education in two scientific fields. One program would fund student research projects based on scientific merit and insight. A…
IRS approves a school-construction set-aside
A private foundation requested approval to set aside funds for construction of a school building serving minority and underprivileged children. The multi-year project included classrooms, a welcome ce…
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.