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Notice 2023-38 and Notice 2024-41 are

SECTION 4. PROCEDURE

Internal Revenue Bulletin 2025-8 · 2026-10-03 edition · updated 2026-10-04 · United States

.01 A taxpayer within the scope of section 3 of this revenue procedure may obtain the automatic consent of the Secretary to revoke its § 831(b) Election by submitting the revocation request described in section 4.02 of this revenue procedure. A user fee is not required for a revocation request submitted under this revenue procedure. The IRS will not send an acknowledgement of receipt for a revocation request submitted under this revenue procedure.

.02 A revocation request is described in this section 4.02 if the requirements of sections 4.02(1) through (4) are met. See section 5 of this revenue procedure for a model revocation request letter.

(1) The request identifies the taxpayer and contains the taxpayer’s taxpayer identification number, address, and telephone number; states that the taxpayer requests automatic consent to revocation of its § 831(b) Election under this revenue procedure; and identifies the revocation year. The revocation year may be the taxable year in which the taxpayer submits the revocation request described in section 4.02 of this revenue procedure, or the first preceding taxable year provided the taxpayer submits the revocation request described in section 4.02 of this revenue procedure no later than the date on which the taxpayer files its timely-filed (including extensions) Federal income tax return for such taxable year. For example, a calendar

26 CFR 601.201: Rulings and determination letters (Also Part 1, § 831)

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▸Contents — Internal Revenue Bulletin 2025-8

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