Sccba buying and selling a business practical tax consequences 110125

1. BUYING AND SELLING A BUSINESSPractical Tax ConsequencesRoger RoyseRoyse Law Firm, PC2600 El Camino Real, Suite 110Palo Alto, CA 94306rroyse@rroyselaw.comwww.rroyselaw.comwww.rogerroyse.comSkype: roger.royseIRS Circular 230 Disclosure: To ensure compliance with the requirements imposed by the IRS, we inform you that any tax advice contained in this communication, including any attachment to this communication, is not intended or written to be used, and cannot be used, by any taxpayer for the purpose of (1) avoiding penalties under the Internal Revenue Code or (2) promoting, marketing or recommending to any other person any transaction or matter addressed herein.

2. OVERVIEW OF TRANSACTIONSTax Free Reorganizations:Type A – Merger Type B – Stock for Stock Type C – Stock for Assets Type D – Spin Off, Split Off, Split Up, and Type D Acquisitive ReorganizationsTaxable Transactions:Stock Sale Asset SaleForeign CorporationsS Corporation StrategiesPartnership Techniques2

3. TAXABLE VS. TAX FREEType of Acquisition Currency Stock Securities/Debt Deferred payments, earnouts CompensatoryNature of the Buyers and Seller Foreign Parties Tax Attributes of PartiesShareholder Level Considerations Tax Sensitivity of Shareholders Appetite for Complexity & Risk3

4. CONTINUITY OF INTEREST4IRS – 50% Safe Harbor, Rev. Proc. 77-37John A. Nelson – 38% StockMiller v. CIR – 25% StockKass v. CIR – 16% Stock is InsufficientValue – 2007 Regulations address changes in value between the date of signing and close; if fixed consideration, (1) stock consideration is valued as of last business day before the first day the contract is binding and (2) if a portion of the fixed consideration is other property identified by value, then the specified value is used for that portion (see Reg. 1.368-1T(e)(2)). Consideration is “fixed” if contract states exact number of shares and other cash or property to be exchangedPost transaction sales and redemptions

5. TAX FREE REORGANIZATIONSType A – Merger

6. Type B – Stock for Stock

7. Type C – Stock for Assets

8. Type D – Spin Off, Split Off, Split Up, and Type D Acquisitive Reorganizations

9. Ruling Guidelines

10. Rev. Rul. 77-37

11. Rev. Proc. 86-42

12. Rev. Rul. 73-54 (terms)

13. Rev. Proc. 89-50

14. Rev. Proc. 96-30 (Type D Checklist)5

15. TYPE A REORGANIZATIONS – SECTION 368(a)(1)(A) STATUTORY MERGERShareholdersTargetAcquirorRequirements:Necessary Continuity of InterestBusiness PurposeContinuity of Business EnterprisePlan of ReorganizationNet ValueTax Effect:Shareholders – Gain recognized to the extent of bootTarget – No gain recognitionAcquiror takes Target’s basis in assets plus gain recognized by ShareholdersBusted Merger – taxable asset sale followed by liquidationStatutory Merger – 2 or more corporations combined and only one survives (Rev. Rul. 2000-5)

16. Requires strict compliance with statute

17. Target can be foreign; Reg. 1.368-2(b)(1)(ii)

18. No “substantially all” requirement

19. No “solely for voting stock” requirement6

20. TYPE B REORGANIZATIONS – SECTION 368(a)(1)(B) STOCK FOR STOCK7ShareholdersAcquiror StockTarget StockTargetAcquirorAcquiror’s basis in Target stock is the same as the Shareholder’s Solely for voting stock

21. No Boot in a B

22. Reorganization Expenses – distinguish between Target expenses and Target Shareholder expenses (Rev. Rul. 73-54)

23. Creeping B – old and cold stock purchased for cash should not be integrated with stock exchangeAcquisition of stock of Target, by Acquiror in exchange for Acquiror voting stockAcquiror needs control of Target immediately after the acquisitionControl = 80% by vote and 80% of each class

24. TYPE C REORGANIZATIONS – SECTION 368(a)(1)(C) STOCK FOR ASSETS8ShareholdersAcquiror StockAcquiror StockTargetAcquirorTarget AssetsAcquisition of substantially all of the assets of Target, by Acquiror in exchange for Acquiror voting stock

25. “Substantially All” – at least 90% of FMV of Net Assets and at least 70% of FMV of Gross Assets

26. Target must liquidate in the reorganization

27. 20% Boot Exception – Acquiror can pay boot (non-stock) for Target assets, up to 20% of total consideration; liabilities assumed are not considered boot unless other boot exists

28. Reorganization Expenses – Aquiror may assume expenses (Rev. Rul. 73-54)

29. Assumption of stock options not boot

30. Bridge loans by Acquiror are boot

31. Redemptions and Dividends – who pays and source of fundsTYPE D REORGANIZATIONS – SECTION 368(a)(1)(D) DIVISIVE SPIN OFF, SPLIT OFF, SPLIT UP9ShareholdersTransferee StockTransferee StockTransferorTransfereeTransferor AssetsDivisive – transfer by a corporation of all or part of its assets to another corporation if, immediately after the transfer, the transferor or its shareholders are in control of the transferee corporation. Stock or securities of the transferee must be distributed under the plan in a transaction that qualifies under Section 354, 355, or 356. TYPE D REORGANIZATIONS – SECTION 368(a)(1)(D) NON-DIVISIVE10Merger Treated as Acquisitive DIf shareholders of Transferor stock receive Acquiror stock and own at least 50% of Acquiror stock, the transaction may be treated as a non-divisive D REORG even if it fails as an A REORG for lack of continuityShareholders with 20%AcquirorStockAcquiror StockTransferorAcquirorTransferor AssetsMergerFailed Type C Treated as DLiquidation / ReincorporationShareholdersShareholders50%AssetsStockAssetsStockAssetsTransferorAcquirorTransferorAcquirorCash & Stock

32. TRI-ANGULAR OR SUBSIDIARY MERGERS111. Forward Subsidiary MergerTPS2. Reverse Subsidiary MergerTPSKey:T = Target P = Acquiror S = Merger Sub

33. TRI-ANGULAR OR SUBSIDIARY MERGERS12Tax Consequences Merger Sub takes Target’s basis in assets increased by gain recognized by Target

34. P takes “drop down” basis in stock of Merger Sub (same as asset basis)T ShareholdersP StockTP80%MergerSub SurvivesSSection 368(a)(2)(D) Forward Triangular Merger A statutory merger of Target into Merger Sub (at least 80% owned by P) Substantially all of Target’s assets acquired by Merger SubWould have been a good Type A merger if Target had merged into PKey:T = Target P = Acquiror S = Merger Sub

35. TRI-ANGULAR OR SUBSIDIARY MERGERS13Tax Consequences Non-taxable to Target and carryover basis

36. No gain to P and Merger Sub under Sections 1032 and 361

37. No gain to Target shareholders except to the extent of boot

38. P’s basis in Target stock generally is the asset basis, but P can choose to take Target shareholders basis in stock (if it is also a B)

39. If transaction is also a 351, P can use Target shareholders’ basis plus gainT ShareholdersP StockTP80%MergerTarget SurvivesSSection 368(a)(2)(E) Reverse Triangular Merger Merger of Merger Sub into Target where (i) Target shareholders surrender control (80% of voting and nonvoting classes of stock) for P voting stock and (ii) Target holds substantially all the assets of Target and Merger SubKey:T = Target P = Acquiror S = Merger Sub

40. TAXABLE STOCK PURCHASES14Cash Reverse Triangular MergerTreated as Stock SaleT ShareholdersCashTPMergerTarget SurvivesSShareholders have gain or lossP takes cost basis in Target sharesKey:T = Target P = Acquiror S = Merger Sub

41. CASH FORWARD MERGER15T ShareholdersAsset sale followed by liquidation of TargetTarget has gain on saleTarget shareholders have gain on liquidation (unless 332 applies)P takes cost basis in Target assetsTPMergerP SurvivesVariation with Merger Sub:T ShareholdersTPMergerSub SurvivesSKey:T = Target P = Acquiror S = Merger Sub

42. NET VALUE RULES162005 Proposed Regulation 1.368-1(b)(1): Exchange of no net value (liabilities exceed value) does not qualify as a reorganizationExample:P owns all of the stock of both S and T. T has assets with FMV of $100 and liabilities of $160, all of which are owed to B. T transfers all of its assets to S in exchange for the assumption of T’s liabilities, and T dissolves. The obligation to B is outstanding immediately after the transfer. P receives nothing in exchange for its T stock. Under paragraph (f)(2)(i) of the Reg, T does not surrender net value because the FMV of the property transferred by T ($100) does not exceed the sum of the amount of liabilities of T assumed by S in connection with the exchange ($160). Therefore, under paragraph (f) of the Reg., there is no exchange of net value. See Prop. Reg. 1.368-1(f)(5) Example 3.Alabama Asphalt

43. SECTION 382 – LIMITATION ON LOSSES AFTER CHANGE IN OWNERSHIP17Section 381 – Survival of Tax Attributes

44. Section 382

45. When there has been an ownership change of a corporation with loss carry forwards, use of Net Operating Losses (NOLs) against future income is limited to the product of the value of the Target and the long term interest rate

46. “Ownership Change” occurs if, within a 3 year testing period, the percentage of stock of Target held by 5 Percent Shareholders increases by more than 50% over lowest percentage held by such shareholders during the test period. NON-QUALIFIED PREFERRED STOCK18Preferred Stock – limited and preferred as to dividends; and does not participate in corporate growth; If:(1) shareholder has right to require issuer to redeem

47. (2) issuer is required to redeem

48. (3) issuer has right to redeem and is more likely than not to exercise that right; or

49. (4) dividend rate varies based on interest rate, or commodity price or other index

50. Redemption right exercisable within 20 years and not subject to contingency that renders likelihood remote

51. Excludes stock compensation that may be repurchased on separation from service

52. Conversion feature not enough to participate in growth

53. Generally treated as boot to shareholdersTARGET DEBT SECURITIES19Exchange of Target securities for P securities is tax free under Sections 354 and 356, to the extent that the principal amount of P debt is less than the principal amount of Target debtPortion attributable to cash basis accrued interest is taxablePossible COD incomeExample:Target bonds with an issue price (stated principal amount) of $1,000 exchanged for P stock or debt worth $900; Target has COD of $100

54. DIVIDEND EQUIVALENCY20Section 356(a)(2) – Boot as dividend or capital gain; post-reorganization redemption test of Rev. Rul. 93-61

55. Clark – hypothetical post-reorganization redemption reduced shareholder’s interest from 1.32% to .92% - substantially disproportionate under Section 302(b)(2)

56. Section 302(b)(1) – redemption that results in meaningful reduction in voting power is redemption and not essentially equivalent to a dividend

57. Section 302(b)(2) – greater than 20% reduction is substantially disproportionate

58. E&P Limitation on Dividend – should be Target’s E&P but unclear if P’s E&P counted; PLR 9118025, PLR 9041086, and PLR 9039029CONTINGENT STOCK, ESCROWS, AND EARN-OUTS21Escrows:

59. Target shareholders usually treated as owner of escrowed P shares unless otherwise agreed

60. especially true if Target shareholders have right to vote and receive dividends

61. not clear who is owner if Target shareholders do not have right to vote or receive dividends

62. Earn-Out Stock:

63. Target shareholders not considered owners until P shares are issued

64. Not treated as boot

65. Imputed Interest

66. Rev. Proc. 84-42 Ruling Guidelines – use of escrow or contingent stock

67. (1) stock must be distributed within 5 years, subject to escrow or contingency

68. (2) valid business purpose

69. (3) maximum number of shares cannot exceed 50%

70. (4) trigger event not controlled by Target shareholders and not based on tax liability

71. (5) Formula is objective and readily ascertainable

72. (6) Restrictions on assignment and substitution

73. (7) In the case of escrows, P shares shown as issued to Target shareholders, current voting and dividend rights, and vested BUSTED 35122T ShareholderShareholdersP StockStockBusinessPMergerTRev. Ruling 70-140Step 1: Incorporate TStep 2: Merge T into P

74. Double Merger23REV. RUL. 2001-46Step 2: A-type forward mergerStep 1: Reverse triangular mergerT ShareholdersT ShareholdersP Stock+cashAcquirorTargetAcquirorMergerSub Survives80%MergerTarget SurvivesMerger SubMerger SubTarget+SubTax Benefit: A taxable reverse merger has just one tax on the shareholders, while a taxable forward merger has two taxes (one on shareholders and one on corporation). Intended that entire transaction be a tax-free A-type merger (where 20% boot limitation does not exist). Pairing the two reduces the risk of incurring the corporate level tax in the event the entire transaction is not treated as an A-type merger.

75. Double Merger – Wholly Owned LLC24REV. RUL. 2001-46Step 2: A-type forward mergerStep 1: Reverse triangular mergerT ShareholdersT ShareholdersP Stock+cashAcquirorTargetAcquirorMergerLLC Survives80%MergerTarget SurvivesLLCMerger SubTarget+SubTax Benefit: A taxable reverse merger has just one tax on the shareholders, while a taxable forward merger has two taxes (one on shareholders and one on corporation). Intended that entire transaction be a tax-free A-type merger (where 20% boot limitation does not exist). Pairing the two reduces the risk of incurring the corporate level tax in the event the entire transaction is not treated as an A-type merger.

76. USE OF WHOLLY OWNED LLC25T ShareholdersP StockTargetAcquirorMergerLLC SurvivesLLCMerger of Corporation into LLC Reg. 1.368-2(b)(1) – by operation of law, all assets and liabilities of Target become those of LLC, and Target ceases legal existence

77. A Type ReorganizationSECTION 351 / 721 ROLLOVER26T Shareholders 80% vote & value

78. taxation of boot

79. debt + non-qualified voting stock

80. assumption of liabilitiesPEGTargetCash out some and rolloverT ShareholdersCashT ShareholdersPEGCashCashTargetPEGT SharesCashAssetsCashNewCoNewCoTargetAssets

81. LLC TECHNIQUESStep 1Step 2T ShareholdersFormer T Shareholders$Target Corp.AcquirorLLCTargetMergerLLC SurvivesLLCTarget27

82. FOREIGN CORPORATIONS28Section 367(a) – outbound transactionsForeign corporation not treated as a corporation except as provided in regulationsGenerally, gain recognized unless:No more than 50% of stock of foreign Acquiror received by US transferors,No more than 50% of stock of foreign Acquiror owned after the transfer by US persons that are officers or directors or 5% Target shareholders,Gain Recognition Agreement ("GRA") is entered into by 5% US transferee shareholders 36 month active trade or business test met, No intent to substantially dispose of or discontinue such trade or business,FMV of the assets of transferee must be at least equal to the FMV of the US target, andTax reportingSection 367(b) – inbound and foreign to foreign transfersUS Acquiror and foreign TargetTarget can be treated as a corporationMay be income to Target’s US shareholders to extent of Target’s accumulated E&P

83. FOREIGN CORPORATIONS29Anti-Inversion Rules – tax outbound reorganization and/or tax foreign Acquiror as a U.S. taxpayer; Code Section 7874If ownership of former U.S. Target shareholders in foreign Acquiror is 80% or more; foreign Acquiror is treated as a U.S. company If ownership continuity is between 60-80%; foreign Acquiror is NOT treated as a U.S. company, but U.S. tax attributes cannot be used to offset gains20% excise tax on stock-based compensation upon certain corporate inversion transactions 7874 exception available for companies with “substantial business activities” in the foreign jurisdiction; facts and circumstances test compares activities of company in foreign jurisdiction with activities of company globallyControlled Foreign Corporations (“CFCs”)A foreign entity is classified as a CFC if it has “United States Shareholders” who collectively own more than 50% of the voting power or value of the company. For the purposes of the CFC rules, a “United States Shareholder” is defined as US persons holding at least a 10% interest in the foreign corporation.

84. 1248 AMOUNT ON SALE OF CONTROLLED FOREIGN CORPORATION30Section 1248 Seller of Controlled Foreign Corporation (CFC) must treat as dividend gain to extent of E&P1248 inclusion carries foreign tax credits1248 amount determined at year end and pro rated based on day count, so post closing events can have an effect on the 1248 amount

85. JOINT VENTURE STRUCTURES31Foreign CompanyUS CompanyCashAssets & LiabilitiesSection 367 IssuesDisguised SaleLLCUS & Foreign Assets

86. INSTALLMENT METHOD32Gain on each payment = gross profit ratio times paymentGross profit ratio = ratio of total gain to purchase pricePre-transaction planning opportunities to utilize basisSection 453A – interest charge to the extent taxpayer holds more than $5 million face amount of Section 453 obligationsSection 453 LimitsNot available for publicly held stock or securities, or inventoryNot available for sales for demand notes or readily tradable notesNot available for instruments secured by cash or cash equivalentsObligor must be purchaser (cannot use parent debt)Section 453 applies unless taxpayer affirmatively elects outSection 453(h) – Target shareholders who receive Acquiror debt in liquidation of Target allowed to use installment reporting

87. CONTINGENT PAYMENTS AND EARN-OUTS33Distinguish Equity vs. Debt3 Issues(1) allocation between interest and sales proceeds;(2) timing of realization of sales proceeds; and (3) timing of basis recoveryInterest 1.1275-4(b)Contingent payment debt for cash or publicly traded property – use non-contingent bond method; projected non-contingent and contingent payments1.1275-4(c)Contingent debt instrument issued for non-publicly traded property – bifurcate into non-contingent debt instrument and contingent debt instrument; contingent payment treated as principal based on present value, excess is interestBuyer’s basis is non-contingent portion plus contingent payments treated as principal

88. CONTINGENT PAYMENTS AND GAIN RECOGNITION34Reg. 15A.453-1(c)If capped by maximum amounts, assume maximum for purposes of gross profit percentage (accelerates gain, backloads basis)If no cap, but term, basis recovered ratably over termIf neither time nor amount is capped, basis recovered ratably over 15 yearsElection out of Section 453 – FMV of contingent obligation is amount realizedOpen transaction treatment – rare and extraordinary situations only

89. SECTION 338 ELECTION35Section 338(g) – Target in stock sale treated as selling all its assets followed by liquidation post close (soaks up NOLs)

90. Section 338(h)(10) – Sale and liquidation deemed to occur pre-close; joint election; S corporation or sale out of a consolidated group

91. Adjusted Grossed-Up Basis – New Asset basis is basis in recently purchased stock (last 12 months) grossed up to reflect minority shareholder’s basis + liabilities of Target (including taxes in 338(g))

92. Adjusted Deemed Sale Price – grossed up amount realized of recently purchased stock plus liabilities of old T (on day after acquisition date)338(g) ELECTIONS36If there is a US Buyer of a foreign owned foreign target, then 338(g) election steps up basis and eliminates E&P and foreign tax creditsTarget may be able to offset 338(g) gains with NOLs

93. PURCHASE PRICE ALLOCATION37Asset Sale or 338 Election

94. Sections 1060 and 338 classes based on FMV

95. Class I – cash and equivalents

96. Class II – actively traded personal property under 1092

97. Class III – debt instruments and marked to market

98. Class IV – inventory

99. Class V – assets other than those in I-IV or VI

100. Class VI – goodwill and going concern

101. Agreement Allocations – Danielson Rule

102. Parties bound by agreement unless IRS determines that the allocation is NOT appropriate

103. SFAS 141R – Purchase Price Allocations

104. Assets booked at FMV as of closing date (not signing date)

105. Bargain purchase results in accounting gain

106. Earn Outs – estimated and recorded

107. Deferred tax assets for excess tax deductible goodwill over book value

108. Transaction related costs recognized (expensed)UNVESTED STOCK RECEIVED IN A TAXABLE OR NON-TAXABLE DEAL38Rev. Rul. 2007-49 - The revenue ruling addresses:

109. (1) the exchange of fully vested stock for unvested stock of an acquiring corporation in a tax-free reorganization, and

110. (2) the exchange of fully vested stock for unvested stock of an acquiring corporation in a taxable exchange

111. Under either (1) or (2), the Rev. Rul. provides that the exchange constitutes a transfer of property subject to Section 83. Thus, the service provider would need to file an 83(b) election to avoid the recognition of compensation income in the future as the shares vest. The Rev. Rul. also provides that the spread will be zero, so there is no downside to the service provider’s 83(b) election. OPTIONS39Assumption or SubstitutionNo tax on substitution of NSONo tax on substitution of ISO, so long as the substitution is not a modification; there is no “modification” so long as (1) the aggregate spread in new option does not exceed the spread in the old and (2) the new option does not have more favorable terms than the old; see Sections 424(a) and 424(h)(3)

112. OPTIONS – CASH OUT40Cancel options for cash paymentNSO Ordinary income – compensation – withholding or 1099Deduction to Target or Acquiror?TAM 9024002 – employer deducts based on method of accounting; not clear if cash out at close is pre-acquisition Target deduction or post-close Acquiror deduction in absence of scripting the timingUnder the cash method, the deduction generally arises when the employer has “paid” the property to the employee. See Regs. §1.461-1(a)(1). Under the accrual method, the deduction arises when the employer's obligation to make the property transfer becomes fixed, the property's value is determinable and economic performance occurs. See Regs. §§1.461-1(a)(2) and -4(d)(2)(iii)(B)ISOFICAExercise and disqualifying disposition treated differently

113. 409A41Deferred compensation

114. A deferral of compensation occurs whenever the service provider (employee) has a legally binding right during a taxable year to compensation that will be paid to such person in a later year. Treasury Regulation Section 1.409A-1(b)

115. Consequences of violating 409A

116. Amounts which were to be deferred are subject to immediate taxation

117. Additional 20% penalty on such amounts

118. Interest penalty

119. CA state tax penalty

120. Bonus or Carve Out Plans

121. Participation in Earn Outs (Reg. 1.409A-3(i)(5)(iv))

122. Payments of compensation in this context may be treated as paid at a designated date or pursuant to a schedule that complies with 409A if the transaction-based compensation is paid on the same schedule and under the same terms and conditions as apply to payments to shareholders generally pursuant to the change in control event280G GOLDEN PARACHUTE RULES4220% excise tax and loss of deduction on Excess Parachute Payment

123. “Excess Parachute Payment” means the amount by which the Parachute Payment exceeds the Base Amount

124. “Parachute Payment” means a payment, the present value of which, exceeds three times the Base Amount

125. “Base Amount” means the average annual compensation for past 5 years

126. Must be paid to a disqualified individual (meaning employee, officer, shareholder, or highly compensated individual)

127. As compensation, AND

128. Contingent on a change in control (50% change ownership or effective control, or ownership change in a substantial portion of the company’s assets)

129. Reduce Excess for reasonable compensation

130. Exclude reasonable compensation for future services

131. Exception for small business corporation and non publicly traded corporation that has 75% uninterested shareholder approval

132. Withholding requirement280G – OTHER ISSUES43Non-Publicly Traded StockApproval of 75% of shareholders after adequate disclosureVote determines the right of the shareholder to the paymentIgnore shares held by persons receiving the paymentReduction for Excess (299% of payments)Reduction for Reasonable CompensationReduction for Future Services

133. S CORPORATIONS AND 338(h)(10)44T ShareholdersCash and Notes Character difference – ordinary income assets

134. California 1.5% tax on S corporations

135. All Target shareholders must consent on Form 8023

136. Deemed 338 election for subsidiaries

137. 1374 – BIG Tax

138. Minority shareholders in rollover

139. Hidden tax in liquidation or deemed liquidation in installment sale.T (S Corp)PReverse subsidiary cash mergerSKey:T = Target P = Acquiror S = Merger Sub

140. S CORP 338(h)(10) ELECTION AND 453B(h) BASIS ALLOCATION ISSUE45Shareholders$1 million basis$1 million cash$4 million 453 NoteTargetAcquirorStock SaleReg. 1.338(h)(10) – 1(e) Example 10Cash - $1 million / $1 million A/BAssets - $4 million / zero A/BGain to Shareholders in year of sale: $1 million x 80% = $800,000; A/B of Shareholder = $1.8 millionNo 331 liquidation: $1 million cash decreases A/B by $1 million to $800,000; $800,000 A/B in Note = $3.2 million gain331 liquidation – apportion basis: $1.8 million basis apportioned $360,000 to cash and $1,440,000 to Note; Gain in cash of $640,000 and gain in note of $2,560,000 for a total of $3.2 million gain (GP % on liquidation is 64%)Defer cash portion and include in installment obligation: gain on liquidation equal to zero; Shareholder A/B in note of $1 million; profit % is 80%

141. S CORP NO 338(h)(10) ELECTION – DISAPPEARING BASIS46T ShareholdersCashLiquidate Target into Merger Sub or check the box Q-SubT (S Corp)PSMergerCarryover BasisKey:T = Target P = Acquiror S = Merger Sub

142. 47PALO ALTO2600 El Camino Real Suite 110Palo Alto, CA 94306SAN JOSE10 Almaden Blvd.Suite 1250San Jose, CA 95113LOS ANGELES10900 Wilshire Blvd.Suite 300Los Angeles, CA 90024SAN FRANCISCO155 Sansome StreetSuite 500San Francisco, CA 94104www.rroyselaw.com

Sccba buying and selling a business practical tax consequences 110125

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