The Pre-Filing Agreement Program (PFA) was designed as a component of the Large and Mid-Size Business 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.

The Pre-Filing Agreement Program –  An Overview

A brief summary of the PFA process from inception (pilot program) to current operation. 

Revenue Procedure 2001-22

A description and explanation of the PFA process

IRM 4.30.1, Pre-Filing Agreement Program

The Internal Revenue Manual describing PFA procedures and processes.

Administrative Process

Activities and Responsibilities

LMSB/NTEU Letter of Understanding

PFA Orientation Guide

An overview of the PFA program to be used during the participating taxpayer/IRS examination team orientation phase.

Reports to Congress

Each year the Department of the Treasury is required to make publicly available an annual report relating to PFA program operations for the preceding calendar year.  This section provides each of those reports.

Announcement 2001-38 – CY 2000 Report to Congress

Announcement 2002-54 – CY 2001 Report to Congress               

Announcement 2003-43 - CY 2002 Report to Congress

Questions

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