Epstein File EFTA01980192: Professional (DS10)

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💨IMPACT LEVEL 1 — MEH

Epstein File EFTA01980192: Professional (DS10)

General DocumentDate unavailableEFTA019801921 keyword hits

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This document contains excerpts from tax guidance regarding qualified tax professionals and their competence to render advice on PFIC (Passive Foreign Investment Company) matters under tax code section 1.1295-3(f). The excerpt discusses conditions under which a shareholder cannot be considered to have reasonably relied on a qualified tax professional, specifically when the professional lacks competence in PFIC tax matters. No specific individuals, dates, or financial amounts are identified in the provided excerpt.

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professional

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PersonKeyword

Excerpt 1

competent to render tax advice with respect to PFIC matters 1.1295-3(f) A shareholder will not be considered to have reasonably relied on a qualified tax **professional**

Excerpt 2

if the shareholder knew or reasonably should have known that the qualified tax **professional**- (A) Was not competent to render tax advice with respect to