The PFA program is a beneficial way to reach agreement on a contentious issue through a cooperative effort before the return is filed. Revenue Procedure 2016-30PDF provides the program guidelines. Taxpayers estimate they save 48% by using this process instead of the traditional audit; the Service estimates savings of 30%. On a scale of 1 to 5, taxpayers report an overall level of satisfaction with the program of 4.7 and 4.6 on the likelihood of recommending the process to others. There is a user fee for participation in the program. The user fee is $174,000. OMB requires a user fee on special benefits beyond those received by the general public. The fee is paid only if the issue is accepted. Any taxpayer under LB&I’s jurisdiction may apply for a PFA; eligible issues are factual and governed by well settled law. PFAs can cover the current and up to four future tax years, but the transaction must be complete. They may also be used to determine the appropriate methodology for determining tax consequences affecting future tax years. PFAs are available on International issues. The most common issues are worthless stock/bad debts, research credit, cost segregation studies, and disposition or acquisition of a subsidiary. Recently we have received several on deduction of settlement costs, fines, and penalties. Following are recent statistics on the PFA program: Since the program’s inception in 2001 through September 2018, we have received 534 applications, accepted 362, and closed 281 with an agreement. The total time to complete a PFA was 664 days in fiscal year 2018. A brief summary of the PFA process is below: The taxpayer can file a request with the Case Manager or PFA Program Manager. The request should include all items listed in Rev. Proc. 2016-30PDF. The application is evaluated by Counsel, the Audit team, and Subject Matter Experts. The Practice Area Director makes the decision to accept or not; there is no appeal to the Practice Area Director’s decision. For more information: Visit the PFA page on IRS.gov under information for Large Business and International Division.