How many times, as your company prepares its federal tax return, do you believe – instinctively or through experience – that a position taken on a particular transaction may raise an issue in a post-filing review? How will the new disclosure of uncertain tax positions on the income tax return impact the IRS view on this position? With a Pre-Filing Agreement (PFA), you have an opportunity to work with the IRS prior to the filing of the return to resolve the tax treatment of issues that would typically be disputed during a post-filing examination.
The value of a PFA lies in the certainty that it brings to the position you want to take and the ability to arrive at that certainty using fewer resources and less money than you would in a post-filing review. To decide which issues to address through a PFA and how to use the process most efficiently, look to the Tax Controversy specialists at Deloitte Tax LLP.
Learn more about our services: IRS Pre-Filing Agreements Consultation