Close · Vertical SaaS

Vertical SaaS 338(h)(10) Elections: An Independent Sponsor's Counsel

Structuring 338(h)(10) Elections on vertical SaaS deals, with the structure protection and capital connectivity an independent sponsor actually needs.

EV range $10M to $200M EV EBITDA $2M to $30M (or run-rate ARR) Audience Buy-side / Sponsor
The deal context

Vertical SaaS deals in the lower middle market run a specific playbook. 338(h)(10) Elections is where the structure either holds or starts to leak.

The typical vertical SaaS platform sits at $10M to $200M EV with EBITDA in the $2M to $30M (or run-rate ARR) range. The thesis runs on platform plus adjacent module acquisitions inside a single end-market. The ARR number on the CIM is rarely the ARR number on the closing balance sheet. Reconcile early.

The moves

How 338(h)(10) Elections actually gets structured.

  1. Run a side-by-side tax model showing the seller's grossed-up purchase price requirement.

  2. Document the election in the purchase agreement, with required IRS forms attached.

  3. Confirm the seller's eligibility, including the consolidated group structure.

  4. Plan the tax gross-up payment, often funded out of the buyer's price.

  5. In vertical SaaS, layer in ARR bridge built before LOI signing as part of the 338(h)(10) Elections workstream.

The common mistake

Demanding a 338(h)(10) without offering the seller a tax gross-up. The election only works if the math works for the seller too.

Jason's take
"338(h)(10) is a buyer benefit you have to pay for. Price it into the LOI, not the surprise column."
Jason Powell · 338(h)(10) Elections
Capital after close

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

After close, the call list for refinancing, recapitalization, and growth equity gets short and known. Jason carries that list.

MONTH 18
Senior refi
MONTH 24
Dividend recap
MONTH 36
Growth equity
YEAR 4–5
Strategic exit
ENGAGE THE PRACTICE

338(h)(10) Elections for Vertical SaaS, on independent sponsor terms.

Independent sponsor counsel that already speaks fluent deal-by-deal economics, structures clean LPAs, and travels with capital markets relationships for what comes after close.