joshua, thank you for these ideas.

The real property owned is a rental property.  It qualifies as a TOB.  So, in my understanding of point #1, the 30% withholding does not apply.  This cite is from your link.

In general, income from real property located in the United States that is owned by a nonresident alien is taxed at a 30% rate if it is not effectively connected with a U.S. trade or business.

#3. He isn't a graduate student yet.

#2. N/A. There is no property tax manager. This is a rental house he owns and lives in. He rents a room.

This client has deepened my belief that I need to narrow the focus of my practice. Although RA and NRA issues aren't too difficult, it is an area that could easily bring blind spots and even lead to errors.  The revenue from this niche isn't very big and I don't think I would even know how to market myself successfully. It's a good problem to have and I enjoy having to think about these different aspects of my practice. It is small but growing. But is it smart growth?

Thank you again.