The Office of Pre-Filing and Technical Guidance (PFTG), within the Large and Mid-Size Business Division (LMSB), is responsible for providing oversight and direction to the Technical Advisor Program, including Technical Advisors and Technical Advisor Managers.

Within PFTG, the Office of Tax Shelter Analysis (OTSA) was established to serve as the Service’s focal point for tax shelter compliance initiatives across Divisions. OTSA is primarily responsible for coordinating and planning tax shelter initiatives and supporting IRS examiners working abusive tax shelter cases. OTSA also serves as a clearinghouse for information received by the IRS on potentially abusive tax shelter activities by both corporate and non-corporate taxpayers. More information may be obtained through the IRS web site.

Technical Advisors and Technical Advisor Managers assist Examiners in identifying, developing and resolving industry specific and cross-industry technical issues, both domestic and international; ensure uniform and consistent treatment of issues; provide educational opportunities to internal and external customers as appropriate; and maintain/develop industry and issue expertise.

Technical Advisor Managers, each responsible for a particular industry or issue area, ensure that the objectives of the Office of Pre-Filing and Technical Guidance and the Large and Mid-Size Business Division are met.

Technical Advisors, each serving as a nationwide expert in a particular industry or issue area, ensure consistent treatment of all taxpayers within their specific industry or issue area. See the LMSB Intranet web site for a current listing of all Technical Advisors and the industry or issue areas they represent.

As the needs arise, the Director, Pre-Filing and Technical Guidance, may authorize the formation of Technical Advisor Studies. The purpose of Technical Advisor Studies is to identify industries or issues that merit inclusion in the Technical Advisor Program. The concept encompasses the identification of unique industry accounting practices and audit techniques, the identification of common issues and their tax treatment, and/or the identification of potential Coordinated Issues. Experienced individuals, specifically selected as Interim Technical Advisors, conduct the studies.

Technical Advisor Meetings are periodic meetings held by Technical Advisors to discuss issues, problems and other matters affecting their industry or issue area. Coordinated through appropriate offices, the meetings will be attended by Examiners, representatives from Appeals and Counsel, and others who would benefit from such meetings.

Industry Directors often hold meetings of Examination Teams that work cases in specific industries; Technical Advisors will support such meetings as requested.

Coordinated Issues may be proposed by Technical Advisors to ensure that key issues within particular industry or issue areas are raised, developed and resolved on a consistent basis. The purpose of Coordinated Issues is to provide Examiners with guidance on significant national issues that are not being resolved consistently. Coordinated Issues establish uniform positions within industry or issue areas. Examiners cannot deviate from such positions without the concurrence of Industry/Issue Teams.

If an issue is industry-specific, the Industry Director responsible for that industry assembles an Industry Team to develop and resolve the issue. If the issue is a cross-industry issue, the Director, Pre-Filing and Technical Guidance, assembles an Issue Team to develop and resolve the issue. The Industry/Issue Team should be composed of Revenue Agents, Technical Advisors, Technical Advisor Managers, Field Specialists, Industry Director representative(s), Appeals, Industry Counsel, Division Counsel and Chief Counsel as appropriate. Additional team members from other Divisions may be included on an ad hoc basis.