Rule 9.46 of the California Rules of Court allows an attorney who is licensed to practice law in one or more jurisdictions of the United States other than California to register to provide legal services in California as in-house counsel exclusively a "qualifying institution" without becoming a member of the State Bar of California. Among other requirements, a "qualifying institution" must have an office located in California.
As a result of the Covid-19 restrictions, many attorneys shifted to working from home. Indeed, many found that they preferred homework to working at the office. Rule 9.46 does not require that in-house counsel work at the qualifying institution's office, but it does require that counsel reside in California. Rule 3.370(D) of the Rules of the California State Bar define "reside in California" as meaning "to live or be located in California on more than a temporary or transient basis". I am not sure why the State Bar believed it necessary to add "or be located" because only deceased counsel would be located in California but not also living.