EXCHANGE MECHANICS

Disqualified person

Also called: disqualified party · agent restriction

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PLAIN-ENGLISH DEFINITION

A person who cannot serve in certain safe-harbor roles because of specified agency or relationship rules.

What it means in practice.

IRS guidance generally treats certain agents of the taxpayer and related persons as disqualified, subject to detailed regulatory definitions and exceptions.

Why it matters.

A familiar advisor is not automatically eligible to act as the QI.

Additional notes.

IRS guidance generally treats certain agents of the taxpayer and related persons as disqualified, subject to detailed regulatory definitions and exceptions.

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