The chart below shows the issues received, accepted into the program, and closed with an agreement during calendar year 2013. Issue Received Accepted Closed Worthless Stock 5 3 2 IRC 41, Research Credit 9 10 4 Cost Segregation Study & Depreciation/Depletion 1 1 2 Gain/Loss on Sale/Exchange of Property/Stock 3 2 5 Deductibility of Settlement /Fine Payments 2 2 Treatment of Identified Mixed Straddle (IMS) transactions 1 1 1 Application of Hedging Rules to Currency Transactions Eligibility to be Treated as a Corporation 1 1 IRC 45, Fuel Credit 1 1 1 IRC 199, Domestic Production Credit Utilization/Amount of NOL 1 1 Medical Device Excise Tax 4 8 Earnings and Profits 1 Tax Consequences of a Merger/Acquisition/Liquidation 2 1 Creditability of Gaming Tax under IRC 903 1 1 1 Offsetting Interest Rate Risk 1 1 1 Deductibility of a Repurchase Premium 1 1 1 Withholding and Reporting Requirements 3 1 1 Whether Taxpayer is a US Real Property Holding Co. 2 1 Characterization of Income 1 The chart below shows the processing time for PFAs during each calendar year. Average Days in Process CY 2005 CY 2006 CY 2007 CY 2008 CY 2009 CY 2010 CY 2011 CY 2012 CY 2013 Screening Process 48 55 53 62 39 57 40 50 67 PFA Evaluation Process 224 292 340 344 235 328 225 342 348 Total Time 273 347 393 406 274 385 265 392 415 The chart below shows the numbers of PFAs received, accepted into the program, and closed with an agreement during calendar year 2013 for each industry. CY 2013 Received Accepted Closed CTM 7 9 6 F 4 3 5 HMP 13 11 4 NRC 7 4 3 RFTH 6 8 4 IBC 1 Total 38 35 22 The chart below shows the number of PFAs received, accepted in to the program, and closed with an agreement during each calendar year since the program’s inception. CY Received Accepted Closed with Agreement CY 2000 19 12 7 CY 2001 26 18 5 CY 2002 44 25 12 CY 2003 42 29 18 CY 2004 38 22 27 CY 2005 53 29 19 CY 2006 46 37 27 CY 2007 29 20 20 CY 2008 32 20 19 CY 2009 28 21 15 CY 2010 23 18 13 CY 2011 39 28 22 CY 2012 33 12 10 CY 2013 38 35 22 Total 490 326 236
