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20 June 2025

Pre-Filing Agreement program for large business and international taxpayers gets upgrades

  • The IRS has improved the PFA program to help resolve potential tax issues before filing returns, including a redesigned landing page and updated program statistics and guidance.
  • Taxpayers must comply with specific requirements to participate, focusing on actual return items rather than hypothetical scenarios.
  • The IRS will typically decide within 60 days whether a taxpayer will be accepted into the program.
 

The IRS has announced (IR-2025-69) improvements to the Pre-Filing Agreement (PFA) program, which is one of the programs the Large Business and International division (LB&I) offers to resolve potential tax issues before taxpayers file their returns. Enhancements include a redesigned PFA landing page, step-by-step filing instructions and updated program statistics and guidance, such as a list of likely suitable issues for a PFA.

PFA program

Taxpayers must request to participate in the PFA program by complying with the listed requirements. The request must concern items that will be on the return, not hypothetical scenarios or future transactions. The IRS will usually decide whether to accept the request within 60 days. Taxpayers accepted into the PFA program must pay a user fee of $181,500.

The announced changes to the PFA program include:

  • A redesigned PFA landing page, which includes an overview of the process, updated program statistics, and direct navigation to dispute prevention resources
  • New instructions on how to submit a PFA request
  • A page that helps taxpayers identify if a PFA request is appropriate for their issue
  • Updated program guidelines to help businesses coordinate their PFA submissions with tax filing deadlines

Implications

The IRS has been working to reinvigorate and improve cooperative tax compliance programs, such as the PFA program. The recent enhancements should lead to greater pre-filing certainty and encourage voluntary compliance. The updates, such as recent statistics and a list of likely suitable issues, provide taxpayers with information to make more educated decisions about whether to request a PFA and a clearer picture of how likely their request is to be accepted.

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Contact Information

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Tax Policy and Controversy

Published by NTD’s Tax Technical Knowledge Services group; Andrea Ben-Yosef, legal editor

Document ID: 2025-1310

 

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