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Pre-Filing Agreement Program

The Pre-Filing Agreement Program (PFA) was designed as a component of the Large Business and International Division’s issue management strategy. Briefly, the program encourages taxpayers to request consideration of an issue before the tax return is filed and thus, resolve potential disputes and controversy earlier in the examination process. The effect of the program is to reduce the cost and burden associated with the post-filing examination, to provide a desired level of certainty regarding a transaction and to make better use of taxpayer and IRS resources. Below are materials which further describe the PFA process, what is required and information concerning the results achieved.

IRM 4.30.1, Pre-Filing Agreement Program

The Internal Revenue Manual describing PFA procedures and processes.

Rev. Proc. 2007-17 has been superseded by Revenue Procedure 2009-14. Rev. Proc. 2007-17 was issued to replace expiring Rev. Proc. 2005-12. It incorporates the increased user fee of $50,000 but does not make significant changes to the program.

PFA Orientation Guide

An overview of the PFA program to be used during the participating taxpayer/IRS examination team orientation phase.

PFA Fact Sheet (March 2014)

Issues Successfully Completed

Reports to Congress

Each year from 2000-2004, the Department of the Treasury was required to make publicly available an annual report relating to PFA program operations for the preceding calendar year. This section provides those reports.

Questions - Any questions may be referred to

Page Last Reviewed or Updated: 17-Mar-2015