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 a renewable local scholarship program
A private foundation proposed scholarships for students from specified counties attending universities, colleges, or vocational and technical schools, with larger awards for agricultural studies. Awar…
IRS approves need-based scholarships for blind students
A private foundation proposed scholarships for legally blind, financially needy U.S. residents pursuing undergraduate or graduate degrees at selected private colleges. A program coordinator would eval…
IRS approves architecture and preservation scholarships
A private foundation proposed annual scholarships for high school seniors in an architecture mentoring program and undergraduates studying architecture, historic preservation, or urban design. Applica…
Artist residency grant procedures receive advance approval
A private foundation proposed an artist residency program with three six-week sessions each year. Selected artists would receive housing, studio access, meals, a stipend, and supply assistance while p…
IRS approves a metropolitan-area scholarship program
A private foundation requested advance approval for a scholarship program serving full-time undergraduate students from a specified metropolitan area. Applicants would be evaluated on academic results…
IRS approves international entrepreneur and artist grant programs
A private foundation requested advance approval for two educational grant programs serving individuals from a foreign country. One program would support entrepreneurs, including women in STEM, who pro…
IRS approves community service educational grants
A private foundation proposed educational grants for faculty, staff, and undergraduate students who showed exemplary character and commitment to community service. Grants could fund educational confer…
IRS approves career-development grants for professional artists
A private foundation proposed taking over part of a regional arts program and making one- or two-year grants to professional artists with a significant body of original work. Applicants would submit a…
IRS approves last-dollar grants for alternative high school graduates
A private foundation proposed a grant program for graduates of a public alternative high school serving an underprivileged student population. Staff-referred students on track to graduate would be eva…
IRS approves medical education grants tied to regional service
A private foundation proposed paying the reasonable professional-school costs of physicians and, in later stages, other healthcare professionals to address a severe regional shortage of medical person…
IRS approves in-kind steer training grants for local youth
A private foundation proposed an educational grant program that would give local youth hands-on experience nurturing and showing steers. Each in-kind grant would cover a steer, feed and medicine, care…
Below-market arts loan is a program-related investment and qualifying distribution
A private foundation proposed an unsecured, below-market line of credit to a foreign alternative investment fund. The fund would use the money for below-market loans to museums, galleries, and other a…
IRS approves scholarships for graduates of five participating high schools
A private foundation proposed scholarships for graduates of five participating high schools who need financial help for full-time post-secondary education. Applicants would submit academic records, re…
IRS approves grants for biomedical research and surgical training models
A private foundation proposed educational grants for biomedical research and the development and validation of surgical training and testing models. Qualified applicants worldwide could seek funding f…
IRS approves multi-year research grants for chemistry and physics faculty
A private foundation proposed fellowship and research grants for mid-career tenured chemistry and physics faculty. University nominees would need relevant expertise, a strong record of achievement, cu…
IRS approves scholarships for students who lost a parent or guardian
A private foundation proposed scholarships for full-time college students and incoming students who had lost a parent, stepparent, or guardian. Applicants had to live in the specified area, maintain a…
IRS approves scholarships for financially challenged students overcoming obstacles
A private foundation proposed scholarships and nonfinancial support for high school students who had overcome significant obstacles and planned full-time college study. Eligible students initially wou…
IRS approves one-time university scholarships
A private foundation proposed one-time academic scholarships for current or incoming students at a specified university. All such students could apply, with preferences for graduates of particular hig…
Literary fellowship and retreat grants receive IRS approval
A private foundation proposed three grant programs for established and emerging writers connected with an annual literary retreat. One program would support a career author for up to three years, anot…
Foreign regranting program qualifies under private-foundation rules
A private foundation planned to fund three foreign charities that would independently select local organizations for projects serving disadvantaged elders, children, teenagers, and other individuals. …
IRS approves museum-project set-aside
A private foundation planned to establish a museum for artwork expected from an individual's estate. It had purchased a building for the museum, but pandemic conditions halted renovation planning, pre…
College scholarship procedures receive IRS approval
A private foundation proposed one-time and multiyear college scholarships, primarily for current students and graduates of specified high schools. A three-person committee would evaluate applicants un…
Nationwide scholarships for women receive IRS approval
A private foundation proposed nationwide scholarships for women pursuing undergraduate or graduate education and demonstrating financial need. Applicants needed a minimum 3.0 grade point average, tran…
Scholarships for minority and first-generation students approved
A private foundation proposed need-based scholarships for minority and first-generation college students connected to a specified community and region. Applicants from targeted neighborhoods needed at…
Community and employee-child scholarships approved
A private foundation proposed one-year regional scholarships and a limited number of scholarships for dependent children of a company's full-time employees. Applicants would be evaluated on academic r…
Scholarship and international skills-grant procedures approved
A private foundation proposed both scholarship grants under Section 4945(g)(1) and educational or skills grants under Section 4945(g)(3). The scholarships could support students from primary school th…
Employer scholarships and community arts grants approved
A private foundation sought advance approval for two grant programs. One would provide renewable postsecondary scholarships to children of current employees, subject to financial need, independent sel…
Foundation may set aside funds for rehabilitation facility
A private foundation planned a multi-year project to buy land and build a rehabilitation and training facility for disabled athletes, wounded veterans, and other people with physical disabilities. It …
Foundation may set aside funds for charter school
A private foundation planned to construct and operate a tuition-free public charter school serving kindergarten through sixth grade, with a possible later expansion. The approval, planning, permitting…
Foundation's last-dollar scholarship procedures approved
A private foundation proposed need-based, last-dollar scholarships for recent high school graduates from a particular community. Awards would cover the gap between estimated education costs and other …
Foundation's upper-level college scholarships approved
A private foundation proposed two-year scholarships for state residents entering their third or fourth college year, or the comparable years of a five-year degree. Applicants had to attend an accredit…
Digital-transition grant procedures approved
A private foundation proposed grants and technical support to help eligible nonprofits and small businesses move their products or services online. Contractors and technology vendors would develop tai…
Foundation's community scholarship procedures approved
A private foundation proposed generally one-year scholarships for foreign-born high school athletes attending a private school in a particular area. Applicants had to maintain at least a 2.0 GPA, demo…
Educational grant procedures receive advance approval
A private foundation proposed instructional study grants, experiential study grants, and hardship-based travel grants connected with its educational programs. The programs used eligibility and selecti…
IRS approves a private foundation set-aside for a classical dance and arts facility
A private foundation asked to set aside funds to acquire and develop a building for classical dance and arts programs. The facility would contain studios and educational space, house administrative wo…
IRS approves college and early-learning scholarship procedures
A private foundation sought advance approval for two scholarship programs under IRC § 4945(g). One program supported graduating high school students pursuing college or trade-school education, while t…
IRS approves scholarship and individual educational grant procedures
A private foundation proposed scholarships under IRC § 4945(g)(1) and educational or talent-development grants under § 4945(g)(3). Its program would support higher education, youth, stronger communiti…
IRS approves scholarship and enrichment grant procedures
A private foundation proposed a scholarship program for higher education and an enrichment grant program for scholars, faculty members, lecturers, and other distinguished scholars. Scholarship recipie…
IRS approves employer-related scholarship procedures
A private foundation proposed scholarships for children and stepchildren of an employer's active full-time employees. An independent public charity would administer the program and select recipients u…
IRS approves conference attendance grant procedures
A private foundation proposed educational grants enabling people in nonprofit, government, educational, and certain creative work to attend its sustainable-development conference. Applicants would des…
IRS approves business scholarship procedures for a high school senior
A private foundation proposed an annual scholarship for a graduating high school senior who planned to attend a four-year college and pursue business or entrepreneurial business studies. Trustees woul…
IRS approves set-asides for two scholarly symposia
A private foundation planned two multi-year symposia that would bring promising young scholars together to discuss work in two redacted academic disciplines. It proposed annual set-asides to accumulat…
IRS approves a private foundation's scholarship and educational loan procedures
A private foundation asked for advance approval of procedures for scholarships and possible future long-term, low-interest educational loans. Its program would primarily help financially needy student…
IRS approves an employer-related scholarship program
A private foundation proposed scholarships for children, dependents, and grandchildren of employees of a company and its subsidiaries. An independent committee would select recipients using academic a…
IRS grants a 60-month extension for a museum relocation set-aside
A private foundation had previously received approval to set aside funds to relocate a museum between two foreign cities. An unexpected donation doubled the museum's collection and increased its space…
IRS approves a regional scholarship program
A private foundation proposed renewable scholarships for high school and college students pursuing their first bachelor's degree in a specified region. Applicants had to demonstrate academic achieveme…
IRS approves multiple scholarship programs
A private foundation proposed several classes of one-time scholarships for graduating high school seniors and one university student. The programs used varied criteria, including academic standing, fi…
Advance approval of an employer-related scholarship program
A private foundation runs a scholarship program for the children and grandchildren of a company's current, retired, or deceased employees, paying grants directly to students pursuing an undergraduate …
Nonvoting LLC interests avoid self-dealing and excess-holdings taxes
A private foundation expected to receive nonvoting interests in an LLC from its donors or their estate. The LLC would hold a promissory note issued by an irrevocable trust connected to the donors, and…
IRS approves a multistate essay scholarship program
A private foundation proposed nonrenewable scholarships for graduating high school seniors in four states who planned to attend accredited four-year colleges or universities. Home-schooled applicants …
IRS approves a COVID-delayed construction set-aside
A private foundation requested to set aside funds for construction and repair projects at two educational properties. COVID-19 shutdowns disrupted active projects and made completion schedules uncerta…
IRS approves weekly community solution grants
A private foundation proposed weekly grants to individuals or teams for research and solutions benefiting residents of three cities. It would publicly announce each application cycle, require a detail…
IRS approves a private foundation's scholarship and individual grant procedures
A private foundation requested advance approval for two programs that make grants to individuals. One program provides scholarships and fellowships for undergraduate or graduate study, while the other…
IRS pre-approves a foundation's grant program funding under-covered labor journalism
A private foundation asked the IRS to approve, in advance, the way it selects and monitors grants made to individual journalists. The program funds reporting on under-covered stories about the U.S. wo…
IRS pre-approves a foundation's scholarship program for civic-leadership students
A private foundation asked the IRS to approve, in advance, its procedures for awarding college scholarships. The program funds the full cost of attendance for high school students who have completed a…
IRS approves a private foundation's additional set-aside for delayed renovation project
A private foundation that runs artist and writer residencies asked the IRS to bless a "set-aside" of funds for a specific project: extensive renovations to its property. Private foundations must pay o…
IRS approves a private foundation's procedures for awarding educational enrichment grants to individuals
When a private foundation makes grants to individuals for study, travel, or similar purposes, those payments are "taxable expenditures" that trigger an excise tax unless the IRS approves the foundatio…
IRS approves a science foundation's multi-year set-aside to fund building a new telescope and observatory
A private foundation generally must pay out a minimum amount each year (its "qualifying distributions") or face an excise tax. Section 4942(g)(2) lets a foundation instead "set aside" money for a spec…
202048010: Advance approval of a private foundation's college scholarship program under § 4945(g)(1)
A private foundation asked the IRS to approve, in advance, the way it will pick and administer scholarships. Private foundations need this approval because a grant to an individual for study can other…
IRS approves renewable scholarships for seniors at two local high schools
A private foundation proposed annual scholarships for graduating seniors at two local high schools. School staff would screen applications for academics, activities, community service, and financial n…
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.