Exempt Organizations - Private Letter Rulings and Determination Letters


Notice: Historical Content

This is an archival or historical document and may not reflect current law, policies or procedures.

In some areas, the law requires that an organization notify the Internal Revenue Service or receive an advance determination before undertaking a transaction resulting in certain tax consequences. Thus, an exempt organization must request a private letter ruling or determination with respect to the following issues:

  • Advance approval of scholarship programs, and certain other grant-making procedures, of private foundations (Internal Revenue Code section 4945(g))
  • Determinations about application of the neighborhood land rule (Code section 514(b)(3))
    Voluntary termination of a private foundation’s status, except by transferring assets to, or operating as, a public charity
  • Status as an exempt operating foundation (Code section 4940(d))
  • Establishment of a set-aside under the "suitability test" (Code section 4942(g)(2))
  • Extension of disposal period for certain excess business holdings (Code section 4943(c)(7))
  • Certain changes in an organization's accounting methods and periods See Publication 4221-PFPDF, for a general discussion of accounting methods and periods. See also Code section 446(e).
  • Advance approval of private foundation’s voter registration activities (Code section 4945(f))
  • Status as an organization described in section 501(c)(3), 501(c)(9), or 501(c)(17). (Code section 508(a).  

A private foundation must also notify the IRS when it intends to voluntarily terminate its private foundation status under Code section 507(a)(1).

Additional information

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