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 and thus, resolve potential disputes and controversy earlier in the examination process. The effect of the program is to reduce the cost and burden associated with the post-filing examination, to provide a desired level of certainty regarding a transaction and to make better use of taxpayer and IRS resources. Below are materials which 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Revenue Procedure 2016-30 superseded Revenue Procedure 2009-14.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 2018)

Issues Successfully Completed

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.

• Pre-Filing Agreement Program Statistics - Calendar Year 2017

• Pre-Filing Agreement Program Statistics - Calendar Year 2016

• Pre-Filing Agreement Program Statistics - Calendar Year 2015

• Pre-Filing Agreement Program Statistics - Calendar Year 2014

• Pre-Filing Agreement Program Statistics - Calendar Year 2013

• Pre-Filing Agreement Program Statistics - Calendar Year 2012

• Pre-Filing Agreement Program Statistics - Calendar Year 2011

• Pre-Filing Agreement Program Statistics - Calendar Year 2010

• Pre-Filing Agreement Program Statistics - Calendar Year 2009

• Pre-Filing Agreement Program Statistics - Calendar Year 2008

• Pre-Filing Agreement Program Statistics - Calendar Year 2007

• Pre-Filing Agreement Program Statistics - Calendar Year 2006

• Pre-Filing Agreement Program Statistics - Calendar Year 2005

• Announcement 2005-42 - CY 2004 Report to Congress

• Announcement 2004-59 - CY 2003 Report to Congress

• Announcement 2003-43 - CY 2002 Report to Congress

• Announcement 2002-54 - CY 2001 Report to Congress

• Announcement 2001-38 - CY 2000 Report to Congress

Questions - Any questions may be referred to pfa.info@irs.gov.