Pre-Filing Agreement Program Statistics - Calendar Year 2006
The chart below shows the issues received, accepted into the program, and closed with an agreement during calendar year 2006. (The number of issues does not match the number of applications since some have multiple issues.)
|
Issue |
Received |
Accepted |
Closed |
|
Worthless Stock |
4 |
3 |
1 |
|
IRC 41, Research Credit |
7 |
6 |
2 |
|
IRC 199, Domestic Production |
7 |
5 |
1 |
|
Cost Segregation Study |
3 |
2 |
3 |
|
Gain/Loss on of Property or Stock |
2 |
2 |
5 |
|
Disposition of Subsidiary |
|
2 |
1 |
|
Acquisition Costs |
2 |
1 |
4 |
|
Donation and Valuation of Intangible |
2 |
3 |
1 |
|
Loss on Seized Assets |
1 |
1 |
|
|
Dividend Received Deduction |
1 |
|
|
|
Abandonment Loss |
|
|
1 |
|
Like-Kind Exchange |
|
|
1 |
|
Effectively Connected Income |
1 |
1 |
2 |
|
Allocation of price on Buyout/Merger |
1 |
|
|
|
Deductibility of Termination Fee |
2 |
1 |
1 |
|
Deductibility of Settlement Payments |
2 |
1 |
|
|
Mark to Market |
1 |
|
|
|
Permanent Establishment |
|
1 |
|
|
Interest Deduction |
|
1 |
1 |
|
Withholding & Reporting FICA, Interest, Dividends |
1 |
1 |
1 |
|
Loss on Portfolio Transfer |
1 |
|
|
|
Adjustment due to Change in Accounting Method |
1 |
|
|
|
Apportionment of General and Admin Expenses |
2 |
2 |
1 |
|
Repatriation of Earnings |
1 |
1 |
1 |
|
Debt Issues |
2 |
2 |
1 |
|
Land Improvements Costs |
1 |
1 |
|
|
Pension Plan Issue |
1 |
|
|
|
Casualty Losses |
1 |
1 |
|
|
Disclosure Issue on Listed Transactions |
1 |
|
|
The chart below shows the processing time for PFAs during each calendar year, since the program’s inception.
|
Average Processing Time (Days) |
Pilot
|
CY 2001
|
CY 2002
|
CY 2003
|
CY 2004 |
CY 2005 |
CY 2006 |
|
Application Screening Process |
38 |
47 |
53 |
59 |
76 |
48 |
55 |
|
PFA Evaluation Process |
242 |
126 |
183 |
240 |
285 |
224 |
292 |
|
Total Time to Complete a PFA |
281 |
173 |
235 |
299 |
360 |
273 |
347 |
The chart below shows the numbers of PFAs received, accepted into the program, and closed with an agreement during calendar year 2005 for each industry.
| CY2006 | Received |
Accepted |
Closed |
|
CTM |
12 |
11 |
7 |
|
F |
13 |
5 |
3 |
|
HMT |
7 |
6 |
6 |
|
NRC |
8 |
7 |
3 |
|
RFPH |
6 |
8 |
8 |
|
Total |
46 |
37 |
27 |
The chart below shows the number of PFAs received, accepted in to the program, and closed with an agreement during each calendar year since the program’s inception.
|
|
Received |
Accepted |
Closed with Agreement |
|
CY 2000 |
19 |
12 |
7 |
|
CY 2001 |
26 |
18 |
5 |
|
CY 2002 |
44 |
25 |
12 |
|
CY 2003 |
42 |
29 |
18 |
|
CY 2004 |
38 |
22 |
27 |
|
CY 2005 |
53 |
29 |
19 |
|
CY 2006 |
46 |
37 |
27 |
|
Total |
268 |
172 |
115 |
