Pre-Filing Agreement (PFA) Program Statistics Calendar Year 2018

 

The chart below reflects the PFA issues received, accepted into the program, and closed with an agreement during calendar year 2018. PFAs accepted may have been received in a previous year; those closed in calendar year 2018 were likely accepted in a previous year.

PFA Issues Received, Accepted and Closed in FY 2018

Issue Received Accepted Closed
Section 956 Inclusion 1 1  
Worthless Stock 1 1  
Change in Accounting Method 1 1  
Foreign Tax Credit  1    
Research Credit      2
Capital Losses      1
Corporate Losses     1
Bad Debt      1

The chart below reflects the processing time for PFAs during each calendar year.

PFA Processing Time by Calendar Year
Average Days in Process CY 2014 CY 2015 CY 2016* CY 2017 CY 2018
Screening Process 29 48 93 103 154
PFA Evaluation Process 384 296 710 531 796
Total Processing Time 413 344 803 634 950

* Two of the five PFAs closed took an average of 172 days in the screening process and 1157 days in the evaluation process.

The chart below reflects the numbers of PFAs received, accepted into the program, and closed with an agreement during calendar year 2018 for each LB&I practice area. PFAs accepted may have been received in a previous year; those closed were likely accepted in a previous year.

PFAs by LB&I Practice Area - Calendar Year 2018
CY 2017 Received Accepted Closed 
Central      
Eastern 2 1 1
Northeastern 1 1 2
Western 1 1 2
Cost Total 4 3 5