Global Daily Tax News, US Improves Large Taxpayer Pre-Filing Agreement Program, (Jun 19, 2025)
The US Internal Revenue Service has announced improvements to the its Pre-Filing Agreement program, which is intended to provide greater tax certainty for large businesses and international taxpayers.
Specifically, the PFA program allows taxpayers under the Large Business and International Division jurisdiction to resolve potential tax issues before filing their return, offering certainty, reducing audit risk, and encouraging voluntary compliance.
The IRS said key enhancements to the Pre-Filing Agreement program include:
A redesigned PFA landing page with program statistics, a streamlined process overview, and direct navigation to dispute prevention resources;
New step-by-step instructions to submit a PFA request, including response time expectations, and post-submission next steps;
A dedicated Pre-Filing Agreement (PFA) likely suitable issues and documentation page, intended to help taxpayers identify if a PFA request is appropriate for their situation; and
Updated program guidelines to help businesses strategically align their PFA submissions with tax filing deadlines.