IRS improves Pre-Filing Agreement tax certainty program for large business and international taxpayers

The Internal Revenue Service today announced improvements to its Pre-Filing Agreement (PFA) program to provide greater tax certainty for large business and international taxpayers.

These improvements mark a renewed commitment by the IRS to expand access to cooperative tax compliance strategies that prevent disputes before they arise. 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.

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 will help taxpayers identify if a PFA request is appropriate for their situation.
• Updated program guidelines to help businesses strategically align their PFA submissions with tax filing deadlines.

To learn more or provide feedback, visit Dispute prevention and resolution for large business and international taxpayers or email pfa.info@irs.gov with the subject line Feedback on PFA Program.

Source: IRS-2025-69, June 17, 2025