For your firm review and state CPA / EA board.

1. Nature of the Platform

Plan Your Passing is a third-party technology and content platform providing estate-planning education to consumers and white-label marketing infrastructure to subscribing tax professionals. The platform itself does not prepare returns, represent taxpayers before the IRS, render tax advice, or hold itself out as a tax preparation service. The platform is owned by Plan Your Passing (5740 Everwood Court, San Pablo, CA 94806), operated by Roger Daniel Grubb, a California-licensed real estate broker with no IRS practice credentials.

2. Nature of the Partner Subscription

The partner tax professional pays a flat monthly SaaS subscription fee ($97–$297/month) for: a co-branded subdomain, a sales-asset library (email scripts, social posts, workshop kit, basis worksheets), and ongoing content updates. The fee is not contingent on any tax engagement, is not a referral fee, is not paid out of any preparation fee, and is not compensation for the recommendation of any tax position or strategy. It is the same category as paying for Lacerte, Drake, UltraTax, CCH Axcess, or a marketing platform like Constant Contact.

3. Circular 230 §10.30 — Advertising Standards

All partner-facing marketing assets provided in the kit are templates designed to comply with §10.30 standards. The partner tax professional is responsible for deploying them consistent with §10.30, which prohibits:

• False, fraudulent, or coercive statements
• Misleading claims about practitioner qualifications
• Misleading claims about tax results obtainable
• Unsubstantiated comparative claims

No template in the kit contains specific tax results, guarantees, or comparative claims. Practitioner identification (name, designation, license number, firm affiliation) appears on every co-branded asset.

4. Hypothetical Revenue Projections (partner-recruitment pages)

The platform's partner-recruitment pages (/for-tax-pros, /partners) display hypothetical revenue projections for partner tax professionals (e.g., $31,100 in new annual estate-year revenue). These are not tax-results claims — they project the partner's own business revenue under stated assumptions, with explicit FTC §437-compliant earnings disclaimers. These projections do not appear in any client-facing materials in the sales kit. Client materials describe tax-planning topics, deadlines, and educational content only.

5. AICPA Code of Professional Conduct

The platform-provided marketing assets are consistent with AICPA Code §1.600 (Advertising and Other Forms of Solicitation). No false, misleading, or deceptive content is included. No promises of specific results. No comparative claims. The partner CPA / firm remains responsible for ensuring deployed assets meet AICPA standards, state board rules (which may be stricter), and applicable independence requirements where attestation services are also provided by the firm.

6. State CPA Board Rules

State CPA boards vary in advertising restrictions. Some states (e.g., Texas, California) require specific disclosures, prohibit certain testimonial structures, or require pre-publication review of marketing material. The partner CPA is responsible for confirming compliance with their state board's advertising rules before deploying any platform-provided asset. Sample state- specific disclosure language is provided during onboarding; the CPA verifies the specific current requirement with their board.

7. Scope of Practice — EAs, CTECs, AFSPs

The kit assets are designed to be used by any tax professional with appropriate IRS practice rights. The tax-content scope (estate income tax returns, final 1040, Form 706, Form 1041, inherited-IRA RMD planning, step-up basis documentation) is fully within the practice scope of:

• CPAs (no restrictions)
• Enrolled Agents (unlimited practice rights before IRS)
• CTECs (California Registered Tax Preparers, with continuing-education compliance)
• AFSPs (Annual Filing Season Program participants, with limited representation rights)

The platform does not differentiate marketing assets by designation — practitioners use their own scope-of-practice disclosures as appropriate (e.g., AFSP participants clearly state they cannot represent clients in audit proceedings outside the returns they prepared).

8. CE Credit for the Workshop

The platform provides workshop content (2-hour Estate-Year Tax Workshop) designed to be eligible for CE credit in many states. The platform does not certify CE itself. The partner CPA / EA applies for CE credit through their state board / IRS-approved sponsor using the workshop template provided. Approval and credit hours are determined by each board / sponsor. Plan Your Passing makes no representation that workshop content will be approved in any specific jurisdiction.

9. Client Confidentiality & §7216

IRC §7216 prohibits a tax preparer from disclosing or using tax return information for any purpose other than preparation without taxpayer consent. The platform-provided client portal collects only information voluntarily submitted by the client (contact details, intake responses, uploaded documents). The platform does not access, mine, or use return data for any purpose other than rendering the technology service to the partner firm. A standard data-processing agreement is available on request. The partner remains the data controller and is responsible for §7216 compliance, including obtaining required client consents.