IRS Issues PLR Granting Foreign Insurance Company Consent to Revoke Domestic Corporation Election

April 6, 2026, 9:20 PM UTC

The IRS has issued a private letter ruling on I.R.C. §953 granting consent for a foreign insurance company to revoke its domestic corporation election effective January 1, 2025, requiring recognition of gain from the deemed property transfer to a foreign corporation under section 367. [PLR 202614011]

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