Best Practices: IRS Enhances Pre-Filing Agreement Program to Boost Taxpayer Certainty- MASSIE Welcomes the Updates!

MASSIE is excited to see the IRS come out with new information regarding its Pre-Filing Agreement program. As we have mentioned for the past year, the IRS would like to encourage more taxpayers to enter PFAs, especially regarding research credits. If you’d like more information, please get in touch with Taylor Eiselin.

IR-2025-69, June 17, 2025

WASHINGTON — 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.

Jason Massie, CPA, Esq.

As the Founder and President of MASSIE R&D Tax Credits, Jason is responsible for the quality, consistency, and integrity of our services. His strategic vision and leadership drive innovation within the company, encouraging collaboration and ne...