IRS Partnerships to Lower Risk

Our professionals have a history of partnering with the IRS through formal Pre-Filing Agreements (PFAs) as well as informal methodology agreements. These informal methodology agreements can be carried forward to future years, similar to PFAs. We work closely with the IRS to cooperatively develop methodologies customized for each client.


We have extensive technological capabilities which are essential in properly analyzing client’s data in complex databases to properly qualify and document our clients’ credit eligible activities. We use repeatable screening techniques to analytically identify credit eligible activities and costs. This is critical in establishing an efficient and repeatable methodology. Our experience in handling big data with large-scale clients means we can easily and securely work with massive amounts of data, effective screening database tools, and project tracking tools for surveys and contemporaneous documentation, effectively lessening clients’ administrative burden.

Through the development of customized tools, we are able to reduce the need for future rework and can increase scalability. We enable SMEs to book meetings with us on their own time, freeing up the tax department to deal with issues more pressing than scheduling, and don’t camp in operations departments – we value every person’s time.

We have a robust CAS team that allows us to do stat sampling under Rev. Proc. 2011-42 as well as the use of stat sampling under a current PFA with a technology company with approximately $6 billion R&D spend. This is substantive in reducing audit costs and risk since the sample units documented under the study are the same units that must be audited by the IRS. Additionally, this can result in a dramatic reduction of operational time involved in the study and the audit. Our seasoned data analysis team will thoroughly mine and analyze your data to discover ways in which we can further simplify your existing approach and reduce administrative burden.

Additional Opportunity

We leverage federal study results to claim and support additional state R&D credits. We have found additional state opportunities for Fortune 500 companies for jurisdictions they missed or overlooked. We work to find the credits you are missing so we can can make sure you are getting all of the benefits that you are entitled to!

We weigh risk and opportunity to develop a plan for increasing and sustaining your credit. Our Managing Director led the PFA engagement that resulted in a successful PFA agreement with the IRS for an Aerospace Defense company. This agreement included the allowance of multiple prototypes sold under LRIP contracts. The allowance of the prototypes sold was under the Trinity Court Case criteria, another study which Mr. Peltzer led. The Methodology agreement for the next four years also included details as to types of contracts in which the company had partial or total risk.

Collaborative Decision Making

We walk together with our clients to ensure that we reach and sustain the best results possible through a transparent coverage of the advantages and disadvantages of each issue and alternative methodology trade-offs. It is important to us that our clients’ know what we are doing – it is not a black box approach. This greatly assists with transition for the client taking as much in-house as preferred.

Tailored Development

We partner with our clients to create a bespoke methodology that precisely integrates with your company, maximizing credit materiality, while significantly minimizing operational impact and risk.