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The JMCPA Assistant is informational only. Always confirm tax, legal, or financial decisions with Josh or a qualified team member.
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Advisory Service

M&A Deal Structures

Asset sale vs. stock sale, earnouts, seller financing, 338(h)(10) elections. The deal structure determines the tax outcome — often hundreds of thousands of dollars between two ways of doing the same transaction.

What it is

M&A deal structuring is the tax engineering of a business purchase or sale. The negotiated price gets all the attention; the structure of how that price flows — asset vs. stock, earnout vs. lump sum, installment vs. cash, deferred comp, escrows — determines the actual after-tax outcome for both sides.

We sit on the same side of the table as your attorney during a deal, focused on the tax structure: what saves the most, what's defensible, what the buyer and seller can actually agree to.

Who it's for

  • Owners selling a business
  • Buyers acquiring a business (asset purchase, stock purchase, or hybrid)
  • Partners exiting a partnership or LLC
  • Founders planning a multi-year transition to an internal successor
  • Anyone considering a 338(h)(10) election

What's included

  • Asset sale vs. stock sale tax analysis for buyer and seller
  • Earnout, installment, and seller-financing structuring
  • 338(h)(10) election analysis when applicable
  • Working capital adjustment and indemnification escrow review
  • Coordination with the transaction attorney through closing
  • Post-close tax planning — basis step-up, depreciation, gain recognition timing

How pricing works

Engagement-based, depending on deal size and complexity. Typically a fixed-fee scoping engagement up front to model the structures, then transaction-based pricing through close. We'll quote both pieces before any work begins.