KPMG article: IRS announces improvements to its pre-filing agreement program
Recent changes to the IRS’s pre-filing agreement program
The IRS offers several options for dispute prevention and resolution to assist taxpayers in achieving certainty and finality for their tax return positions. In June 2025 the IRS announced improvements to the pre-filing agreement (PFA) program.
In Notice 2000-12, the IRS announced a pilot program for PFAs for large taxpayers. The purpose of the pilot program was to determine if taxpayers and the IRS could resolve, before a tax return was filed, issues that were likely to be disputed in a post-filing examination. In other words, the parties could engage in a prefiling examination designed to be faster and more efficient, providing certainty, before any post-filing examination occurred.
Read a July 2025 article* prepared by KPMG LLP tax professionals that discusses the recent changes to the IRS’s pre-filing agreement program.
* This article originally appeared in Tax Notes: Procedurally Taxing (July 2, 2025) and is provided with permission.