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.

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.


Any questions may be referred to