Pre-close · B2B Services

F-Reorganization Tax Structuring Counsel for B2B Services Acquisitions

Securities and M&A counsel for independent sponsors structuring B2B services transactions, from LOI to close to the capital markets that open up afterward.

EV range $8M to $90M EV EBITDA $2M to $18M Audience Buy & Sell-side
The deal context

The economics on a B2B services platform deal usually hinge on a handful of structural decisions. F-Reorganization Tax Structuring is one of them.

The typical B2B services platform sits at $8M to $90M EV with EBITDA in the $2M to $18M range. The thesis runs on recurring revenue service platform with bolt-on operators. Most B2B services deals look better in the CIM than in the data room. Skip the CIM, ask for the contracts.

The moves

How F-Reorganization Tax Structuring actually gets structured.

  1. Map the F-reorg sequence with tax counsel before sign-and-close timing locks in.

  2. Confirm state-level treatment, especially in California and New York.

  3. Document the new entity as a flow-through structure that the buyer can step into.

  4. Sequence shareholder approvals to avoid blowing the reorganization treatment.

  5. In B2B services, layer in MSA assignability mapped customer-by-customer as part of the F-Reorganization Tax Structuring workstream.

The common mistake

Trying to retrofit an F-reorg after the LOI is signed. The sequencing has to be planned, not reverse-engineered.

Jason's take
"F-reorgs are clean tax mechanics. Get them on the whiteboard the day you sign the LOI."
Jason Powell · F-Reorganization Tax Structuring
Capital after close

The deal is one thing. The capital that opens up after close is another.

Most independent sponsors solve the closing capital and then run into the post-close capital problem alone. The capital markets relationships that matter at month 18 are part of this practice.

MONTH 18
Senior refi
MONTH 24
Dividend recap
MONTH 36
Growth equity
YEAR 4–5
Strategic exit
WORK WITH JASON

Bring the B2B services deal. Get F-Reorganization Tax Structuring done right.

Direct counsel from a securities and M&A attorney with billions in structured transactions, the independent-sponsor-native playbook, and the capital markets network that opens up post-close.