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@sjrcpa wrote:

@Just-Lisa-Now- I think it depends on the ownership. If you and I own an LLC it's easy.

If there is a tiered LLC, it may be hard to determine who the owners are and get the required info, etc. And that determination could be UPL. Sometimes that's why they're tiered - to mask the true ownership.

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Ahh, ok, I hadnt considered that.  And yes, thats probably the purpose for this all along, to see who's actually hiding in all these tiered companies and the little people got caught up in the hullabaloo.