IRS Expands Pre-Filing Agreement For Large Business
Large and Mid-Size Business division taxpayers seeking to resolve certain tax
issues prior to filing their tax returns may now do so for up to four years under
the IRS Pre-Filing Agreement (PFA) Program.
The PFA program is designed to permit a taxpayer to resolve the treatment of
an issue before the filing of a return. According to the IRS, the program reduces taxpayer burden and makes more effective
use of resources by eliminating tax controversy before the tax return is filed
and providing certainty that agreed upon tax positions will not be challenged
during the post-filing examination process. “We have expanded the PFA program based on suggestions we received from
taxpayers regarding how the IRS could improve the program,” explained
Large and Mid-Size Business Commissioner Deborah M. Nolan. “The changes reflect our focus on reducing taxpayer burden and, where
possible, resolving issues during the pre-filing process,” he added. Other issue resolution procedures, such as the Accelerated Issue Resolution
(AIR) Program or Early Referral to Appeals, remain available to taxpayers who
are not eligible for the PFA program or who are unable to reach an agreement
through the PFA program. .
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