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The Competent Authorities of the United States and the Swiss Confederation enter into the following Agreement (¡°Agreement¡±) concerning the ownership requirements under paragraph 3 of Article 22 (Limitation on Benefits) and paragraph 7 (In reference to paragraph 6 of Article 22 (Limitation on Benefits)) of the Revised Memorandum of Understanding (¡°MOU¡±) of the Convention Between the United States of America and the Swiss Confederation for the Avoidance of Double Taxation with Respect to Taxes on Income, signed on October 2, 1996 (¡°Treaty¡±).

IR-2004-21, Treasury and IRS Shut Down Abusive Life Insurance Policies in Retirement Plans

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Who is subject to discipline under Circular 230? Attorneys, certified public accountants, enrolled agents, enrolled actuaries, enrolled retirement plan agents and registered return preparers are subject to the rules of Circular 230, Regulations Governing Practice before the Internal Revenue Service. These practitioners are subject to discipline under Circular 230 for failing to comply with these rules. Appraisers and any person who gets paid to prepare all, or a substantial portion, of a document relating to a taxpayer¡¯s tax liabilities for submission to the IRS are also subject to discipline under Circular 230 for failing to comply with the rules.

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