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Baudtender
04-24-2003, 11:31 AM
We were discussing corporate structure in a different thread
and I thought it might be useful to branch off into a new area
that holds a lot of interest to folks in our industry.

In our business, the bottom line is that we are big targets for
a myriad of different kinds of lawsuits - personal injury, liquor
liability, product liability, ADA, sexual harassment and other
employment concerns, and a whole bunch more that makes
my stomach churn to think about.

Many years ago, I had started the process of buying a
failing bar/restaurant/nightclub when my lawyer and accountant
put on the brakes. "Are you nuts? You need to incorporate!"
they said. That's when they sat me down and really enlightened
me about the way the world works, and why I needed to cover
my assets personally in such a high-exposure venture.

I have to say, I was awfully dismayed to hear how many of their
clients had been sued out of business, but thankfully didn't
lose their personal savings, homes, etc. thanks to having the
corporate veil. I started doing some thinking about this and
wasn't much reassured that even the corporate veil didn't
protect the business. I had remember reading about a strategy
in a book (I think it was called "Outfox The Foxes" or something
like that) and decided to see if it could be applied to the
hospitality industry. We tweaked it and refined it a bit to make
it workable for our particular circumstances and our industry.

A couple of disclosures here: I'm neither a lawyer nor an
accountant, so don't take any of this seriously until you get
proper analysis and professional counsel. If there's a hole
in this strategy, I haven't found it yet, but that doesn't mean
that one doesn't exist. Every lawyer and accountant I talked
about this with were awestruck - they had never heard of such a
thing, and it struck me by the looks on their faces that they
(especially the lawyers) regard it as both a thing of beauty as
well as personally terrifying.

It's called the Double Corporation Gambit, as far as I can
remember, and here's how it works. As the name suggests, you
will create 2 corporations, we'll call them Corp A and Corp B.

You start off by creating Corp A with minimal stock value, and
capitalize it through personal loans. You file UCC-1 liens against
Corp A for the full amount. Corp A then purchases all of the
property and assets of the proposed business - everything
except for the liquor licenses and operating stock. Then you
create Corp B, again with minimal stock value. Corp A then
loans Corp B its necessary venture capital needs, which Corp
B uses for starting funds, and to purchase the liquor license and
operating inventory. Corp A leases the property and contents
to Corp B. Corp A then also files UCC-1 liens against Corp B, for
the full value. You want these liens to be as large as possible,
and there are lots of legal ways to create true debt above and
beyond the initial cash movement. The UCC-1 filings work just
like a bank's first mortgage on your house. If the home has to be
sold to pay its owners' debts, the bank gets first crack at the
proceeds of the sale of its assets to satisfy their liens.

Since Corp B is leasing from Corp A, and both are controlled by
the same folks behind the corporate veil, it is perfectly proper
to write a lease that, well, doesn't benefit Corp B very much. In
fact, your whole goal is to make Corp B appear to be as debt-
ridden as possible, and holding a wretched and worthless
lease to boot.

Enter Snake Lawyer. He has a client who stubbed his big toe in
the parking lot and figures, due to intense personal
embarassment, pain and suffering, emotional distress, and loss
of consortium with his wife, that he's going to take Corp B
to the cleaners. As he prepares his suit, he does an asset
search on Corp B and discovers that it has nothing but huge
debt that's worth way more than its paltry assets. Let's just say
lawyers generally don't sue homeless people, and for the same
reason Snake Lawyer finds no hope for a fat contingency
percentage and slithers off. Since it happened in the parking
lot, he may try to go after the landlord Corp A. Bang, same
story. The shareholders personally? Whoops, the old corporate
veil has been meticulously managed and stands firm (but see
my warning below.)

If Snake Lawyer tries to play hardball and looks for a settlement,
you just tell him "Come on down and I'll sign over all the Corp
B shares to your client right now. But be warned that Corp A
(or higher up the ladder, the investors) will then hit them for
immediate full payment of their demand notes, and if your client
can't come up with these huge amounts, there will be a Sheriff's
Sale on Corp B and once the debts are settled (to Corp A or
the Corp A investors) there won't be anything left for your client
except shattered dreams, legal fees, and a bum big toe, and
the investors will have everything of value that they started with.
In effect, you've created a legal tar pit.

Now, you don't have to play the same hardball game, you can
be magnaminous and say "Hey, I feel bad about your client's
big toe. I think it's only proper that I cover your client's trip to
the doctor for a big toe splint as well as the day off work he took
to go there." Let your own morality and sense of fairness be
your guide - the attacker is not in control. Whether or not you
pay for him being embarrassed or not getting laid is up to you
and I have no particular advice to offer on that matter.

This is just the overview, but it has the essential working
mechanics - there's a lot of details that have to be filled in by
smart lawyers/accountants. Originally, I felt that if the thing
truly had merit, I could get rid of liability insurance altogether,
but I have to admit I never had the guts to do that. About a
year ago, I was shopping for a new insurance company, and
stopped in to see a fellow club-owner to see who they were
using. He looked at me strangely and laughed. "What's so
funny?" I asked. "I'm using your Double Corporation Gambit,
I don't have any liability insurance." I must have had a few
beers way back when and told him about it, but couldn't
remember it for the life of me. "How's it working for you?" I
asked, keeping a straight face. "We've had about a dozen
threatened bullshit lawsuits in the last 10 years, and every
last one of them disappeared just like you said." He then
confessed that he had passed it along to a whole bunch of
other club/bar/restaurant owners, and I was more than a bit
horrified to hear that this strategem was not only being
attributed to me, but also was becoming the local stuff of legend
before I had total confidence in it myself.

Warning - if you are an employee/officer of any corporation,
you may need to have special insurance to cover you personally,
whether or not you use this strategy or any other. Perhaps
the best place to start would be to ask your attorney how they
would attack this, and then ask them how they could refine it to
make those sorts of attacks distasteful.

So, I'm not telling anyone to do this (I don't want it on my
conscience) and don't particularly claim that it has any merit
at all, but rather throw this out for intellectual dissection and
discussion.

There it is, have fun.

Baudtender

Pilot
04-25-2003, 10:13 AM
(Disclaimer - I am not an Attorney either)
I am not open yet but I have already planned a similar set up except I use 3 C Corporations. Corp A is Nevada Based, Corp B is Nevada based and Corp C is a local State domestic C filing (not saying where) Corp A is the marketing and Royalty based Corp, Corp B is the leasing company and C is the actual Bar.
Here's my set up plan; Corp A is a Nevada C Corporation and is the company that does the marketing and also provides all the manuals and operations systems - Corp A has 2 contracts with Corp C for use of systems for royalty payment, the other contract is performance based marketing contract that has a baseline breakeven then X percentage over that to Corp A - Nevada has no corporate state income tax and that money is upstreamed clean to Corp A - Corp B is the leasing company that leases everything to the bar, also corp B loans money to the bar (UCC filings) to operate. Why 3 you say well a couple of reasons but here's the primary reasoning - Corp A can upstream clean as Royalties and marketing can be claimed out of state (some states argue this but fed law has numerous overullings of such state violation of fed law and Corp B has to file a local foreign corp filing along with a state corp income tax filing.

Other major advantages to C Corps - you decide your fiscal year - in my case Corp A's year ends June 30 - Corp B is January 31 and Corp C is August 31 (only C Corps can do this not Sub S's or LLC's as they are personal flow through tax returns. This allows movement of money and dividends for tax implications.

Also Corp A (My main baby, I have 100% of it) owns 40% of corp B allowing corp A to only have to claim 20% of the B dividend when paid for tax purposes and corp A owns 40% of corp c for the same reason.

Pitfalls - Control group issues - in a nutshell since I own 100% of A I can only own 79.99% of Corp B and 79.99% of Corp C or they become parent subsidiary for tax purposes thus losing some of the liability veil and tax implications. Gifting stock as I did must be exacting in that spouses and children do not count other owned and will be viewed as your own. Also whoever has 20.1% of B cannot own 20.1% of C or a brother sister controlled group exists - again this is very complex but is well worth the effort.

Same as baud mentioned all A and B contracts with C are in A and B's favor with 30 day out clauses for no cause. Basically they would get the bills and some liquor bottles.

I have read and planned this for over two years now while accumulating capitol to set up my little pub. All the corps are now set up. Corp A was set up 2 years ago (Capitolization reasons) and B was set up a couple of months ago and the actual bar corp paperwork came in last week.

I completed my contracts between A and C and B and C yesterday! This was so wierd to read bauds post this morning and it makes me wonder if baud has a camera in my office! I am personally capitolized to a point that I may open in the next couple of months.

There are other advantages and disadvantages so this must be thoroughly discussed with an attorney and CPA. Also make sure you talk to an attorney that practices in C Corp Law same as a CPA. I say this because most Attorneys and CPAs will say LLC is the way to go - the reason for this is Professionals, Attorneys, CPAs, engineers etc CAN NOT be C Corps to practice their trade as professionals and therefore really don't fully get it or want to get it as well as some CPAs I have seen are actually jealous because you can do it and they can't. Sub S and LLC's are calendar year for taxes and are flow through tax returns vice stand alone.

Read Read Read, then consult with your attorney and CPA - that way you'll ask the right questions.

C Corporations are not a game and should be taken very seriously - You must have all you meetings, maintain all minutes, file all your apaerwork on time and act like a C Corp or all advantages will be pierced. If you are just going to set up and leave the paperwork in a file folder somewhere you liability is not as protected as you think.

Great minds think alike, I am
Pilot

David
04-25-2003, 01:37 PM
OK. My post will be short. After all, I have a headache after reading the two previous post and trying to keep everything straight. I even wrote it down on paper as I went. Great post you two. Keep up the great work.

The structuring on the Corporate setup looks legal. There is only one thing to keep in mind. Liquor Licenses can not be leased. You can pen an agreement on a Managers Contract though.

For Example:

If you own a License, you can use that license as a buy in for a venture. You can also own the license and manage the establishment. You can't own a license and not have some form of ownership in the business that the license is in use in. I'm sure that this is how it works in most ABC regulated states. Also, in most states, you, as and individual or corporation, can only hold one liquor license in any given township.

Like everyone has suggested, ask an attorney for his/her opinion.

Bubba's lonely, but no one needs to go to jail.

Fraud and common scheme are very serious felonies. If convicted, you won't be able to hold a liquor license anymore.

cayucos cowgirl
06-07-2006, 12:18 AM
Just wondering how this is all holding together. I mean since the dust has not, (and may never,) settled over Enron, not to mention corp. crackdowns, is this still possible? I know it is not anything to do with ripping off investors, but the law is the law. If that law says someone can sue you for stubbing a toe; well geeze, call an ambulance and then your lawyer. Unless.....Hey, I hope this is working.

I can tell you all kinds of stories of people trying to sue me for the stupidest things. When I get drunk and hurt myself, no matter how bad, I blame my hand for lifting the glass to my lips. What a bunch of fricking cowards they are. :mad:

rkerdza
06-07-2006, 12:49 PM
If it is legally possible with the new corporation laws, then I think the issue isn't so much trying to avoid liability, but to make it so unlucrative (Is that a word?) to sue the business, that the person looking for a "pain & suffering" lawsuit will find it unattractive to pursue the lawsuit. It won't stop someone who wants to sue you just to make a point. Imagine if you serve a minor and he gets drunk and smashes his car and dies. I'm sure MADD or some other special interest group would hand over some money to the grieving mother's lawyer to sue the business and make an example out of them.

Club Security
06-07-2006, 11:41 PM
Hello Everyone,

Well.... interesting posts... very interesting. If you know me, then you know I am definitely not an attorney either but I do have a comment or two.

First... who was it that said; "If it looks to good to be true; it probably is"? Well, I don't know who said it but I sure found that it's true.

I have worked as an expert witness for both sides of the fence surrounding liquor liability. In big and small cases the snake attorney's do their home work and find who to sue for the money. If it is Corp B and Corp C along with Corp A.... they will do it. At minimum they will find that the names on the filing paperwork are all the same... there is no such thing as a real corporate vial. But it sure sounds good....

And finally... NEVER EVER talk about "schemes" or possible "questionable" legal dealings... NEVER. The house built of cards will fall pretty fast when this post ends up on an attorney's message board... and it will. Take a page from the hundreds of organized crime trials... When known crime bosses were sitting on the witness stand and were asked about The Mafia or their involvement in same the answers were; "Mafia... What Mafia, I don't know what you're talking about." This statement also eventually failed because someone talked.... just like leaving a detailed statement on a message board.

Good Luck and Be Safe,

Robert
www.handsalliance.com

allanjustallan
06-08-2006, 11:17 PM
Enron is going to be a small ripple compared to the comming problems at Fannie mae and Freddie Mac.

Just my opinion,

Allan.

SomewhereInAug
06-08-2006, 11:41 PM
Seems a bit much and I agree with the statement if it seems to good to be true, it probably is. However, having a corporation that owns everything withing the club (equipment) and rents it to the bar or club and does the proper UCC filings is not doing anything but simply owning two seperate businesses. You can still be sued of course and I can't imagine not having the liability insurance but worst case scenerio you should loose your equipment or property over a law suit if structured properly. Even better if your wife / husband can own the property and you own the business and just lease the premesis/equipment on a monthly basis for a large payment.

MainSqueeze
06-09-2006, 08:28 PM
Actually, there really is such a thing as a corporate veil, and the way Baudtender and Pilot have explained it is a smart way of achieving it to the fullest extent of protection possible. In this day and age of so many "sue happy" people and lawyers, it's a perfectly legal (and sensible!) way of protecting the assets of an establishment in our industry. To compare it to Enron is way off; the Enron boys were found guilty of FRAUD. This corporate setup is perfectly legal. It's certainly not "too good to be true." It simply is true; it's the way smart businesspeople can set up their businesses so they can minimize the damage of some ridiculous, frivolous lawsuit. Is this a legal "loophole"? Should this corporate structure be illegal? ..I dunno. But until it is, there's nothing wrong with it and in fact is a legal way to keep one's house from falling. But the comparisons of this to Enron and the mafia are just wrong.

Wanna know what's legal, but still wrong and should be changed? I know of a club that was sued because one of its patrons called another customer (who happened to be a huge, muscular black man) the wrong n word, and then proceeded to get his jaw permanently "rearranged". The police were called as soon the staff saw something was wrong, and the club's security and staff were right on top of it immediately, trying to break up the resulting scuffle. Still, the man with the hammered jaw proceeded to sue, based on a lawyer's recommendations. The club's insurance company offered to pay for the patron's medical bills, but no, that wasn't good enough. The lawyer just had to convince the instigator to "throw it up on the wall and see if it'd stick".

Well, once the jury heard the n word in testimony, you could sense a sigh in the entire courtroom, as if each of the jury was saying to themselves "what are we doing here". You could even sense it in the snakey lawyer. He was no fool; he was obviously knowledgeable in the way of "scheming". His next, immediate tactic was to mention the word "adjuster" while he was riffling through his notes, at which time the defense attorney promptly objected, because in this jurisdiction, any mention of anything having to do insurance is immediate grounds for dismissal of the case altogether.

Now can you see why a businessperson might want to take whatever legal steps are available in order to most protect his/her assets? Security, we're talking about one's own personal assets being subject to a frivilous lawsuit such as this one. Would you want your house and every other asset of any value that you've worked hard for subject to being taken because of the idiocy of one individual and his shyster lawyer? Again, to compare this "scheme" (defined among other things as "a systematic or organized framework" by Merriam-Webster) to the mafia or to anything fraudulent such as what Enron's leaders did is just plain wrong. Setting up 2 or 3 companies to work together with each other is really just pretty good business sense. "Asset protection" is a primary objective of any corporate structure, actually.

Anyway, just in case you'd like to know, the insurance company representing the club in the case I've mentioned agreed to settle, once the case was dismissed due to "technicalities", figuring that it would cost another $20k or so to retry the case and that it was just better since they had no backbone to do the right thing, to go ahead and pay off the snake and his "client" (who probably got a mere pittance of the settlement). By the way, all that happened late in the day, in early afternoon, so the judge went ahead and let the jury make a ruling without them knowing the case had been settled, and in under 40 minutes of deliberation, they ruled against even any medical payments.


..just my $0.02 worth. Your mileage may vary

intensity
06-13-2006, 03:01 PM
By the way, all that happened late in the day, in early afternoon, so the judge went ahead and let the jury make a ruling without them knowing the case had been settled, and in under 40 minutes of deliberation, they ruled against even any medical payments.


..just my $0.02 worth. Your mileage may vary


Thats a whole nother can of worms. The outcome of the trial is nul and void. Even if I know for a fact I can win, why bother paying 10,000-15,000 dollars in lawyer and court costs not to mention the stress of the entire ordeal. Basically, as soon as you sue a business in America, you can plan on getting 10k just to settle, right or wrong.


Anyway, don't let me get this thread off track.

BostonDave
09-15-2008, 10:09 PM
This thread is really interesting.

Is anybody still using this type of corporate structure? Anybody have any stories or additional comments regarding this?

If you own the property and the bar business, what is the best way to structure the 2 businesses. We are planning on LLC for Real estate and Sub S corp for business based on attorney and accountants suggestions...is this best option based on your experiences?

ministry
09-16-2008, 10:27 PM
all this a b c stuff gave me a headache. talk to your atty.

intensity
09-17-2008, 08:44 AM
I miss baudtender. His posts were always interesting.

BARTENDER 54
09-17-2008, 06:47 PM
I believe I asked this quite a while back but what happened to Baudtender???

Just kinda wonderin' he seems like he's got it together.

Have a GREAT week,
Rick

rkerdza
09-18-2008, 07:55 PM
I had to laugh when I looked back and saw allan's post about Freddie Mac & Fannie Mae. Very prophetic!

Oxrock
09-20-2008, 01:18 AM
June 8th, 2006: Enron is going to be a small ripple compared to the comming problems at Fannie mae and Freddie Mac.

Just my opinion,

Allan.

Holy F'n Crap! You've got to be kidding me! I've been following you since we opened about the same time but I didn't know you had a crystal ball!!!!!!!

Man oh Man Allan!