CAN2112. Practical Impact of Section 280E Litigation on Structuring and Due Diligence

This panel will discuss resolved and unresolved Section 280E litigation, with a focus on how Section 280E litigation needs to be considered in due diligence, transactions, and tax reporting. After laying that groundwork, we will cover the pros and cons of common structures. This panel will also discuss the impact of cannabis industry regulatory compliance on structuring, transactions, and financial reporting.

Learning Objectives:

• Understand the IRS's evolving position on the impact of Section 280E on tax inventory accounting and the unresolved questions involving the application of Section 280E
• Identify the pros and cons of flow-through and C corporation structures in the cannabis industry.
• How to develop a comprehensive approach to planning and structuring taking into account regulatory and financial reporting requirements.