IRS Expands Pre-Filing Agreement Program

The Internal Revenue Service has expanded a program aimed at enabling some business taxpayers to resolve certain tax issues before they file their returns.

Under revised Pre-Filing Agreement Program guidelines, the agency said that Large and Mid-Size Business Division taxpayers seeking to resolve certain tax issues prior to filing their tax returns can do so for the current taxable year and up to four future taxable years. The LMSB Division serves business taxpayers with assets greater than $10 million.

"We have expanded the PFA Program based on suggestions we received from taxpayers regarding how the IRS could improve the program," said 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."

According to the IRS, the PFA Program aims to reduce taxpayer burden and make more effective use of IRS resources by eliminating tax controversy before the tax return is filed, and providing certainty that agreed-upon tax positions won't be challenged during the post-filing examination process. Other issue-resolution procedures, such as the Accelerated Issue Resolution Program or Early Referral to Appeals remain available to taxpayers who aren't eligible for the PFA Program or who are unable to reach an agreement through the program.

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