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KPMG article: Update to prefiling agreement program

How taxpayers can use the prefiling agreement (PFA) program to prevent tax disputes and gain certainty before tax returns are filed

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december 1, 2025

Faced with the need to continue enforcement efforts, both in closing examinations and opening new ones, the IRS has made a further change to the prefiling dispute prevention option known as the prefiling agreement (PFA) program.

Read a November 2025 article* that examines how taxpayers can use the PFA program to prevent tax disputes and gain certainty for one or more issues before their tax returns are filed. The article also addresses the potential for increased use of the industry issue resolution (IIR) program, which may be more attractive today than in the past.

For more information on how taxpayers can resolve their postfiling tax issues, read TaxNewsFlash.

*This article appears in Tax Notes Federal (November 17, 2025) and is provided with permission.

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