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 thus, resolving potential disputes and controversy earlier in the examination process. The program’s effect is to reduce the cost and burden associated with the post-filing examination, provide a desired level of certainty regarding a transaction, and to make better use of taxpayer and IRS resources. Below are materials that further describe the PFA process, what is required and information concerning the results achieved.

  • Revenue Procedure 2016-30 superseded Revenue Procedure 2009-14. Section 3.09 expands the scope of a PFA to include issues relating to changes in methods of accounting requested pursuant to the automatic change procedures.
  • IRM 4.30.1, Pre-Filing Agreement Program – The Internal Revenue Manual describing PFA procedures and processes.
  • PFA Orientation Guide – An overview of the PFA program to be used during the participating taxpayer/IRS examination team orientation phase.
  • PFA Fact Sheet (January 2023)


Any questions may be referred to