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KPMG article: Postfiling update on dispute prevention and resolution options

How taxpayers can resolve postfiling tax issues in a timely and efficient manner

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november 10, 2025

As part of the IRS’s strategic plan, and needing to continue its enforcement efforts both in closing examinations and opening new ones, the agency has made further changes to its postfiling dispute resolution programs and the Large Business and International (LB&I) Division examination process.

Read a November 2025 article* that examines those recent changes in the context of how taxpayers can resolve their postfiling tax issues in a timely and efficient manner. In particular, it addresses:

  • The heightened approval requirements necessary to deny fast-track settlement (FTS)
  • Clarifications concerning the accelerated issue resolution (AIR) program
  • The new post-Appeals mediation (PAM) pilot program
  • The phaseout of the acknowledgement of facts information document request (AOF IDR)
  • The rapid Appeals process (RAP) program (which may be more attractive today than in the past)

*This article appears in Tax Notes Federal (October 27, 2025) and is provided with permission.

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The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act upon such information without appropriate professional advice after a thorough examination of the particular situation. KPMG LLP does not provide legal services.

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