August 11, 2025
This comprehensive memorandum outlines the IRS Fast Track Settlement (FTS) program and its strategic implications for various taxpayer categories following significant 2025 changes. It explains that FTS aims to resolve tax disputes collaboratively, interrupting the traditional, lengthier process by involving Appeals officers early as facilitators. The document details category-specific rules, exclusions, and strategic considerations for Large Business & International (LB&I), Small Business/Self-Employed (SB/SE), and Partnership taxpayers, highlighting the crucial impact of the elimination of the Acknowledgment of Facts (AOF) process for LB&I. It emphasizes that successful FTS navigation now requires a nuanced understanding of these procedural shifts, resource constraints, and pilot programs, moving away from a one-size-fits-all approach to dispute resolution
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