CONTACTS:

The user fee is $50,000 for taxpayers selected to participate in the LMSB PFA program. Payment is due within 15 

business days of notifi cation that the issue is accepted.

Offi ce of Pre-Filing & Technical Services

Melanie Perrin (202) 283-8408

 Fax (202) 283-8406

Go to www.irs.gov/businesses and click on Information 

for Large and Mid-Size Businesses. Look for Pre-Filing 

Agreement Program to get all the information on the PFA 

process and what is required.

FIND OUT MORE:

“This PFA provides the company and our shareholders a 

level of fi nancial certainty that has traditionally not been 

available to a company until it has been audited by the 

IRS.”

“I compliment the IRS on the creation of a process 

that can be a winner for both the taxpayer and 

the government.”

Taxpayers participating in PFAs estimate savings of 48 

percent of the time they would have spent on the same 

issue in a post-fi ling audit. The IRS estimates a time savings of 30 percent.

On a scale of 1 to 5 (with 5 being the highest), taxpayers 

rate the PFA process as follows:

4.7 on overall level of satisfaction

4.6 on likelihood of recommending to others

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Pre-Filing 

Agreement Program

WHAT TAXPAYERS ARE SAYING:

Pub. 4527 (Rev. 6-2006)

Catalog Number 48469N

www.irs.gov

Providing Certainty

USER FEES:
PFA PROGRAM:

The Pre-Filing Agreement (PFA) program enables taxpayers to request consideration of tax issues before fi ling a 

return. Both taxpayers and the Internal Revenue Service 

(IRS) work together to resolve potential disputes earlier in 

the pre-fi ling process instead of during post-fi ling examinations. 

All taxpayers under the jurisdiction of the IRS Large and 

Mid-Size Business (LMSB) Division are eligible to apply 

for a PFA. Both Coordinated Industry and Industry cases 

are eligible.

A PFA can address an issue for the current taxable year 

plus the four next years, and even a prior year for which 

the return is not yet due and fi led. It can also address a 

methodology or certain international issues. Eligible tax 

issues generally include those that are factual in nature 

and governed by well-established law.

The LMSB Industry Director or the Director of Field Operations will make the decision whether to accept or decline 

a taxpayer’s request for a PFA. Once accepted, a closing 

agreement is executed, which is a binding agreement as 

to the treatment of that issue.

A taxpayer whose request for a PFA is declined may not 

appeal that decision. However, a taxpayer not selected 

for the PFA program remains eligible for other early issue 

resolution procedures including the Accelerated Issue 

Resolution (AIR) Program or Early Referral to Appeals.

The PFA program is taxpayer initiated and LMSB Industry 

driven. Oversight is provided by the Director, Pre-Filing 

and Technical Guidance.

BENEFITS TO THE TAXPAYER:

Pre-fi ling audits are quicker than post-fi ling audits.

Records are current and people are readily available 

who worked on the transaction.

Cooperative relationship develops between the taxpayer and the IRS.

Tax treatment of the issue will be certain to both parties at the end of the process.

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BENEFITS TO THE IRS:

Records are current and complete for examination 

purposes.

Individuals who worked on the transaction are available for interview.

Cooperative relationship develops between the audit 

team and the taxpayer.

Disputable issues are removed from future audit 

cycles allowing for shorter taxpayer examinations 

later on. 

Resource allocation improves.

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PFA PROCESS:

Revenue Procedure 2005-12 gives detailed information 

taxpayers must include in a request for a Pre-Filing Agreement. The following are key points:

Must contain basic identifi cation and other information as outlined in the Revenue Procedure.

Must contain a separate written statement for each 

potential issue, providing specifi c details as outlined 

in the Revenue Procedure.

Must include a standard perjury statement.

Must include a statement of agreement indicating 

that the PFA inspection of records will not preclude 

or impede the IRS from later examining any return or 

inspecting any records.

Must be signed by the taxpayer or Power of

Attorney (POA).

Must submit the request to the LMSB Team Manager if an examination is currently underway. Otherwise, mail or fax requests to the PFA Program 

Manager as instructed in the Revenue Procedure.

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