Continuing coordination. After a request for a PFA has been accepted, the LB&I Practice Area Director having jurisdiction over the PFA request will, through the examination team and local counsel assigned to the PFA, coordinate and consult with the Associate Chief Counsel having subject matter jurisdiction over the issue proposed to be determined by the PFA to ensure that the issue remains suitable for a PFA. The LB&I Practice Area Director will, through the examination team and local counsel assigned to the PFA, inform the Associate Chief Counsel if, at any time after a request for a PFA has been accepted, the facts that are relevant and material to the issue significantly change or, in the case of agreements for future taxable years, any factual assumptions that may be appropriate significantly change.
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Samples: www.irs.gov, my.kiplinger.com, www.irs.gov
Continuing coordination. After a request for a PFA has been accepted, the LB&I Practice Area LMSB Industry Director having jurisdiction over the PFA request will, through the examination team and local counsel assigned to the PFA, coordinate and consult with the Associate Chief Counsel having subject matter jurisdiction over the issue proposed to be determined by the PFA to ensure that the that issue remains suitable for a PFA. The LB&I Practice Area LMSB Industry Director will, through the examination team and local counsel assigned to the PFA, inform the Associate Chief Counsel if, at any time after a request for a PFA has been accepted, the facts that are relevant and material to the issue significantly change or, in the case of agreements for future taxable years, any factual assumptions that may be appropriate significantly change.
Appears in 2 contracts
Samples: www.irs.gov, www.irs.gov