IRS Pre-Filing Agreement & Compliance Assurance Program

Risks and Benefits of Giving Auditors an Advance Look

Recording of a 100-minute CPE webinar with Q&A

Conducted on Wednesday, March 21, 2007

Course Materials


U.S. companies seeking to avoid a prolonged IRS audit can leverage two government advance-review opportunities: the pre-filing agreement, or PFA, program and the compliance assurance program, or CAP.

Under PFA, taxpayers can ask the IRS to examine and resolve tax positions that it's likely to challenge before companies file their returns. PFA provides protection against future IRS penalties, and PFA issues may be resolved for the next four years.

Under the CAP, taxpayers work with the IRS large and mid-sized business division to resolve the proper tax treatment of controversial transactions throughout the year – in effect, a real-time audit.

If companies approach these programs realistically, there are substantial potential benefits. Companies get a clear read on their federal income tax liability for a given year within months, rather than years. Overall compliance costs and fees should be lower.

Listen as our expert panel of tax advisors discusses all aspects of the PFA and CAP programs to help you decide whether your company should enroll.



You’ll leave the teleconference equipped to evaluate these and other critical issues:

  • The potential downside to inviting the IRS an advance insider’s view of your company’s tax compliance. How protected are you, really?
  • What kinds of experiences have participants in these programs reported.
  • Evaluating which tax positions and transactions should, from your company’s perspective, be part of one of these programs.
  • How to write a beneficial closing agreement with IRS input.


Kevin Johnson
Kevin Johnson
Miller & Chevalier

He specializes in federal tax controversies and domestic and international tax planning. He represents large corporate...  |  Read More

David Bowen
David Bowen
Tax Partner
Mayer Brown Rowe & Maw

He specializes in federal tax controversies and transfer pricing. Ge previously served as special counsel to the...  |  Read More

Steve Whiteaker
Steve Whiteaker
Manager, Tax Shelter Analysis Program
Internal Revenue Service

He previously served as manager of the PFA program.

 |  Read More