The beneficial ownership reporting requirement established by the Corporate Transparency Act has created a fair amount of chaos concerning whether providing reporting services to clients is the unauthorized practice of law (UPL). While some state bar associations have come down on one side or the other as to whether certain types of reporting are UPL, the Treasury offers no clear guidance. What the IRS has made clear recently is that Circular 230 ethical obligations extend to matters beyond what the Loving case determined was “practice before the IRS.”
When Your Client’s World Is Bigger Than the U.S.
Manasa Nadig, EA
A lot of client meetings still start with the same assumptions: W-2 in a U.S. state, mortgage nearby, a 401(k), maybe some RSUs, and a college-savings plan. Yet many of those “simple” clients now own an apartment in another country, freelance for a foreign company, or have parents wiring money from overseas. The tax code does not see those details as background color; it treats them as organizing facts. This is where citizenship, residency, and domicile quietly step onto center stage. For planners, the challenge is not memorizing every cross-border rule. It is knowing when a client is no longer “just domestic” and shifting your planning framework before you stumble into penalties, double taxation, or blown opportunities.
