BUSINESS ORGANIZATIONS Chapter 12 Meiners, Ringleb & Edwards The Legal Environment of Business, 12th Edition ©2015 Cengage Learning. All Rights Reserved. May not be scanned, copied or duplicated, or posted to a publicly accessible website, in whole or in part. CHAPTER ISSUES o Major forms of business organizations o How businesses are created o Factors that may influence a business’s choice of its type of organization o Alternative business forms to apply to various circumstances o See Exhibit 12.1 ©2015 Cengage Learning. All Rights Reserved. May not be scanned, copied or duplicated, or posted to a publicly accessible website, in whole or in part. SOLE PROPRIETORSHIPS o o o o o o o o o A person doing business for him/herself (sole proprietor) Usually the proprietor owns all of the business property Responsible for control of the business Responsible for management Responsible for liabilities/debts May hire agents – liable for them as well Capital must come from the owner’s own resources or is borrowed Profits from the business are taxed personally to the proprietor Record keeping formalities are at the owner’s discretion ©2015 Cengage Learning. All Rights Reserved. May not be scanned, copied or duplicated, or posted to a publicly accessible website, in whole or in part. PARTNERSHIPS Definition: An association of two or more persons to carry on business as co-owners for a profit Partners or General partners control the operations & profits Equal control unless agreed differently Under most state laws, a partnership may be sued as an entity. Most states have adopted the Uniform Partnership Act (UPA) and Revised Uniform Partnership Act (RUPA). ©2015 Cengage Learning. All Rights Reserved. May not be scanned, copied or duplicated, or posted to a publicly accessible website, in whole or in part. PARTNERSHIPS o No required to enter into a formal agreement for a partnership to exist at law o However, agreements are preferable, especially regarding finances, management and dissolution issues o If the Partnership Agreement is silent, the UPA governs (“default rules”). Each of the partners has a fiduciary duty to other partner(s) Latta v. Kilbourn: One partner may not use partnership assets for own benefit If the agreement does not state otherwise, the profits of the partnership are divided equally. ©2015 Cengage Learning. All Rights Reserved. May not be scanned, copied or duplicated, or posted to a publicly accessible website, in whole or in part. CASE ZHOU V. BICKLEY Bickley worked at a Yamaha shop. Frequently ate lunch at a Chinese restaurant where Zhou and Zhang (Chinese immigrants) worked. Bickley told Zhou and Zhang that the Yamaha shop was going out of business. Suggested they help him open a new motorcycle repair shop. Three of them signed two-year lease on building for the shop. Zhou and Zhang paid security deposit & 1st month’s rent. They helped pay for inventory; helped get the shop ready. Gave Bickley more money when he asked for it. Soon after Zhou and Zhang asked for keys to building; Bickley refused. Asked to see receipts and invoices; he refused. Asked to work at the shop; he refused. Demanded a written agreement; he refused. Attorney sent a demand letter on behalf of Zhou and Zhang; he ignored it. Suit was filed. Demanded return of funds expended. Bickley counterclaimed for breach of contract by his partners. Trial court held: No partnership, only “a vague agreement to open a motorcycle repair shop.” Bickley operated as a sole proprietor who borrowed money that he owed to Zhou and Zhang. Bickley appealed. (Continued) ©2015 Cengage Learning. All Rights Reserved. May not be scanned, copied or duplicated, or posted to a publicly accessible website, in whole or in part. CASE ZHOU V. BICKLEY Mere fact parties called themselves partners and refer to business as a partnership, doesn’t make them partners or a partnership. Zhou, Zhang and Bickley contributing money for expenses and signed a lease, is no binding contract, much less a partnership. A reasonable person could conclude that Zhou and Zhang simply intended to enter into a partnership agreement in the future. Bickley denied Zhou and Zhang access to building; denied them access to financial records; refused to let them participate in the operations of business. Such actions not consistent with a partnership. Affirmed: Parties did not intend to do things that would constitute a partnership. Intent to do things which constitute a partnership determines if parties are partners. ©2015 Cengage Learning. All Rights Reserved. May not be scanned, copied or duplicated, or posted to a publicly accessible website, in whole or in part. TERMINATION OF THE PARTNERSHIP Dissolution occurs when an event takes place to dissolve the partnership. Change of the composition of the partners Withdrawal of a partner Bankruptcy of a partner concerning the business Death of a partner Winding up of the partnership involves completing any unfinished business. If terminated, partnership must be reformed. Common: Partnership purchases life insurance on partners Proceeds used to buy back the interest of deceased partner from her estate ©2015 Cengage Learning. All Rights Reserved. May not be scanned, copied or duplicated, or posted to a publicly accessible website, in whole or in part. LIMITED PARTNERSHIP Definition: 2 or more persons (partners) who have entered into an agreement to carry on a business venture for profit MUST have a written agreement that is filed with the state. Called Certificate of Limited Partnership. Puts 3rd parties on notice that limited partners assets not available to satisfy claims against the LP General partners (at least one) Manage the business; Are personally liable to creditors; Have the duty to account to the limited partners Limited partners (at least one) are investors only Do not manage the business; Are not liable for debts beyond their contributions Limited partners BECOME general partners at law IF they participate in or manage the business (lose their limited liability). Most states use some form of the Uniform Limited Partnership Act (ULPA) or Revised Uniform Limited Partnership Act (RULPA). ©2015 Cengage Learning. All Rights Reserved. May not be scanned, copied or duplicated, or posted to a publicly accessible website, in whole or in part. CASE EAGLES LANDING DEVELOPMENT, L.L.C. V. EAGLES LANDING APARTMENTS, L.P. Eagles landing Development LLC (Eagles) contracted to build apartments for Eagles Landing Apartments, LP (ELA) for $1.4 million. ELA’s general partner was Bluff City. Two limited partners, PNC, (a limited partnership) & Columbia (a corporation). Eagles completed work but still was owed $931,000. Agreement stated that Bluff City’s contribution wouldn’t exceed net cash flow from rental of apartment. Cash flow was not good; no money there. All cash invested in ELA by partners was gone. Eagles sued for contribution by PNC and Columbia. Trial Court Held: ELA owed the $931,000. ELA appealed. (Continued) ©2015 Cengage Learning. All Rights Reserved. May not be scanned, copied or duplicated, or posted to a publicly accessible website, in whole or in part. CASE EAGLES LANDING DEVELOPMENT, L.L.C. V. EAGLES LANDING APARTMENTS, L.P. Columbia and PNC argue that if full developer’s fee is due under the Development Agreement, they were not parties to it. They were only limited partners Contend they can’t be charged for any liability of partnership under Development Agreement. Court agreed. Unlike general partners, a Limited Partnership (LLP) protects partners registered as limited liability partnerships. Partner in a registered LLP is not liable. As partners in an LLP, neither Columbia nor PNC can be held liable for partnership debts. Trial court appeared to disregard PNC and Columbia’s status as LLPs. HELD: Affirm trial court’s judgment and amount of $ owed. Reverse assessment of judgment to PNC and Columbia Remand to trial court for purpose of entering judgment against only the partnership, ELA. ©2015 Cengage Learning. All Rights Reserved. May not be scanned, copied or duplicated, or posted to a publicly accessible website, in whole or in part. TERMINATING A LIMITED PARTNERSHIP o Similar to the termination of a general partnership o Death, insanity, withdrawal of a limited or general partner will terminate o Bankruptcy of a general partner = termination o Bankruptcy of a limited partner does not o Organization must wind up the business o Creditors are paid and profits are dispersed according to agreement ©2015 Cengage Learning. All Rights Reserved. May not be scanned, copied or duplicated, or posted to a publicly accessible website, in whole or in part. CORPORATIONS o Legal “entities”/”persons” o Can sue & be sued o It has liability o It has constitutional rights • o Except the privilege against self-incrimination (only officers & employees have that right) MUST meet formal requirements according to state statutes • States issue corporate charter. o Liable for agents’ actions and contracts o Each state has its own corporation laws; federal government places very limited role ©2015 Cengage Learning. All Rights Reserved. May not be scanned, copied or duplicated, or posted to a publicly accessible website, in whole or in part. CREATING A CORPORATION o o o o Articles of Incorporation and an application are sent to the appropriate state office • Name & Address of corporation • Name and Address of registered agent • Purpose of business • Class(es) of stock and par value • Names & Addresses of incorporators The state issues a Certificate of Incorporation Incorporators hold a first organization meeting At the first meeting • Elect a Board of Directors • Enact bylaws or rules that govern internal operations (bylaws cannot contradict the Articles of Incorporation) • Issue the corporation’s stock ©2015 Cengage Learning. All Rights Reserved. May not be scanned, copied or duplicated, or posted to a publicly accessible website, in whole or in part. RELATIONSHIP OF THE PARTIES Important Separation • Of ownership (the shareholders) • AND of control (management & board of directors) Shareholders Owners of the corporation; no day-to-day control of activities Shareholder meetings need quorum (usually more than ½ total shares present) Most shareholders give their proxy to 3rd parties to represent them. Shareholders elect Board of Directors No legal relationship to creditors Board of Directors Have management power over large decisions Can be removed from office by shareholders for cause (breach of duty/misconduct) Have fiduciary duty of loyalty to the shareholders Managers Appointed/hired by directors to manage day-to-day decisions Have broad duties of care & loyalty to directors Employees: Workers ©2015 Cengage Learning. All Rights Reserved. May not be scanned, copied or duplicated, or posted to a publicly accessible website, in whole or in part. BUSINESS JUDGMENT RULE Makes directors & managers immune from liability WHEN problems result from honest mistakes in judgment IF there is a reasonable basis for their decisions IF they act in good faith ©2015 Cengage Learning. All Rights Reserved. May not be scanned, copied or duplicated, or posted to a publicly accessible website, in whole or in part. CASE STORETRAX.COM, INC. V. GURLAND Gurland founded Storetrax.com – internet-based commercial real estate listing service in Maryland in 1998. Incorporated as a Delaware corporation in 1999. He agreed for a group of investors to buy majority share. Became president and member of the Board of Directors. Employment contract said that he had a year’s worth of pay in case he was fired. Two years later, he was removed as president, but stayed on the Board for another year. Requested severance pay, but was denied it. He sued. Board claimed he was not due severance pay because his job duties, title and salary changed. Also, as Board member, they claimed he breached a fiduciary duty by suing the company. Lower Court Held: For Gurland. Storetrax appealed. (Continued) ©2015 Cengage Learning. All Rights Reserved. May not be scanned, copied or duplicated, or posted to a publicly accessible website, in whole or in part. CASE STORETRAX.COM, INC. V. GURLAND o HELD: Affirmed. o There is a fiduciary duty of directors to the corporation. o However, situations arise where a corporate director may proceed with an individual interest that may conflict with those of the corporation on whose Board he sits. o When conflicts of interest arise, courts look closely if director’s dealings are in “good faith and fair dealing”. If conflict arises, director can find a “safe harbor” by disclosing to the corporation the conflict and important facts to the remaining shareholders or directors. o Gurland had a conflict as an aggrieved former employer and his duty as director of the corporation. o Gurland’s seeking $150,000 severance pay was not in corporation’s best interest, HOWEVER o Gurland notified Storetrax sufficiently of imminence of lawsuit. o Gurland’s notification gives him the protections of “safe harbor”. o HELD: Gurland receives severance pay. ©2015 Cengage Learning. All Rights Reserved. May not be scanned, copied or duplicated, or posted to a publicly accessible website, in whole or in part. TERMINATING THE CORPORATION Voluntary Approval of the shareholders and the Board of Directors Articles of Dissolution are filed with the state Involuntary The state dissolves it Bankruptcy “Wind up” business to pay creditors and disburse profits to shareholders ©2015 Cengage Learning. All Rights Reserved. May not be scanned, copied or duplicated, or posted to a publicly accessible website, in whole or in part. CLOSE CORPORATION VS. S CORPORATION S Corporation Close Corporation 20 states allow Distinguished from a “closely held corporation” (See Ch. 18) Limited # of shareholders – 30-50 Shares not sold openly Shareholders must have agreement that governs affairs Not subject to formal rules regarding shareholder and director meetings (unlike regular corporations) Regular C corporation can elect with IRS to be classified as S Corporation Have only one class of stock No more than 100 shareholders Only natural persons (U.S. citizens or legal residents) can be shareholders – not another corporation or partnership Primarily for tax considerations Profits/losses allocated to shareholders who pay income taxes Very popular in smaller businesses ©2015 Cengage Learning. All Rights Reserved. May not be scanned, copied or duplicated, or posted to a publicly accessible website, in whole or in part. PROFESSIONAL CORPORATIONS o Created by state laws o Owners of PC can only be professionals involved in the firm itself (i.e. MD’s whose practices are tied together o Created to have limited liability for its members o Example: Doctors join to reduce liability risk for malpractice of a member-doctor o Stock usually not sold to outside investors o Has special tax treatment with IRS ©2015 Cengage Learning. All Rights Reserved. May not be scanned, copied or duplicated, or posted to a publicly accessible website, in whole or in part. BENEFIT CORPORATION New Class of Corporation Voluntarily meets high standards of purpose, accountability and transparency. Characteristics (1) Corporate purpose to create a material positive impact on society and environment (2) Required to consider impacts of their decisions on shareholders, workers, community & environment (3) Required to make available to public annual benefit report assessing their overall social and environmental performance against a 3rd party standard This entity gives its leadership greater leeway in making decisions that may not comport with traditional standard of maximizing financial interest of the firm. ©2015 Cengage Learning. All Rights Reserved. May not be scanned, copied or duplicated, or posted to a publicly accessible website, in whole or in part. LIMITED LIABILITY COMPANIES LLC is treated like a corporation for liability purposes but like a partnership for federal tax purposes. State laws have procedures to create LLC’s Filing a document: Articles of Organization State issues a Certificate to operate as an LLC Usually is formed by two or more members Members have a membership interest Limited liability of owners – the same as a corporation Members enter into an Operating Agreement An LLC does NOT have perpetual life Death, resignation retirement, expulsion of member terminates LLC If remaining members give consent, LLC can continue (should be set out in Articles of Organization) Termination: There is a period of winding up, followed by payment of creditors and distribution of profits. Similar to bylaws of a corporation ©2015 Cengage Learning. All Rights Reserved. May not be scanned, copied or duplicated, or posted to a publicly accessible website, in whole or in part. CASE IN RE 1545 OCEAN AVENUE, LLC 1545 Ocean Avenue LLC formed for real estate project Owned 50-50 by two companies (Ocean Suffolk & Crown Royal) Each company had membership certificate in 1545. Operating agreement had no dissolution provisions Two managers appointed to operate 1545: Crown Royal appointed King; Ocean Suffolk appointed Van Houten King and Van Houten argued; King announced Crown Royal would pull out King sued for work to stop and the LLC too be dissolved Trial court granted King’s requests Ocean Suffolk and Van Houten appealed. (Continued) ©2015 Cengage Learning. All Rights Reserved. May not be scanned, copied or duplicated, or posted to a publicly accessible website, in whole or in part. CASE IN RE 1545 OCEAN AVENUE, LLC LLCL 702 (New York LLC Law) states that court must examine the LLC’s operating agreement Unilateral action of a single manager was permitted in Article 4.1 of 1545 LLC Operating Agreement Lets each manager to act autonomously to bind LLC in furtherance of business of the LLC Operating agreement was silent re: manger conflicts 1545 can only dissolved if cannot further purpose of LLC HELD: Lower Court ruling reversed; proceeding dismissed. Dissolution is not granted. ©2015 Cengage Learning. All Rights Reserved. May not be scanned, copied or duplicated, or posted to a publicly accessible website, in whole or in part. KEY ORGANIZATIONAL FEATURES o Limited liability o Control o Capital considerations o Taxation o Transferability of ownership interests o Method of creation o Entity as a distinct status separate from its owner o Each owner must make his/her own choice ©2015 Cengage Learning. All Rights Reserved. May not be scanned, copied or duplicated, or posted to a publicly accessible website, in whole or in part. LIMITED LIABILITY Allows a person to invest in a business without placing their personal wealth at risk. Allows investors to be passive toward internal management. Sole proprietors and general partners have unlimited personal liability for debts of business, including torts. Liability of limited partner is limited to capital contributed to limited partnership. Shareholders of corporation and members of limited liability companies risk only their capital investment if corporation fails – generally not personally liable for the business debts or torts. ©2015 Cengage Learning. All Rights Reserved. May not be scanned, copied or duplicated, or posted to a publicly accessible website, in whole or in part. LIMITED LIABILITY Piercing the corporate veil Affects limited liability organizations Prove corporation is a sham Owners actually intend to operate the business as a proprietorship or partnership Can involve fraud, undercapitalization or failure to follow corporate formalities Result: Owners are personally liable for all corporate liability – torts, contracts, debts See KC Roofing Center v. On Top Roofing, Inc. ©2015 Cengage Learning. All Rights Reserved. May not be scanned, copied or duplicated, or posted to a publicly accessible website, in whole or in part. CASE K.C. ROOFING CENTER V. ON TOP ROOFING, INC. Nugents owned a series of roofing companies. Russell and wife only shareholders, directors & officers 1977: Russell Nugent Roofing Inc. was incorporated; 1985: Corporation name changed to On Top Roofing; 1987: On Top Roofing ceased doing business; 1987: Nugents did business through new corporation RNR, Inc. 1988: Replaced by RLN Construction, Inc. 1989: RLN Construction was replaced by Russell Nugent, Inc. Business was run out of Nugent’s home In 1986 Nugents paid themselves salaries over $100,000 each Charged corporation $99,290 in rent for space in their home K.C. Roofing was owed $45,000 for roofing supplies sold to On Top Roofing, which no longer existed. (Continued) ©2015 Cengage Learning. All Rights Reserved. May not be scanned, copied or duplicated, or posted to a publicly accessible website, in whole or in part. CASE K.C. ROOFING CENTER V. ON TOP ROOFING, INC. K.C. asked court to pierce the corporate veil and hold Nugents personally liable. District held for K.C. Nugents Appealed. HELD: Affirmed. Nugents must pay K.C. When corporation is used for an “improper purpose . . . to perpetuate injustice” and “avoid its legal obligations”, corporate veil is pieced. Here: 1. Nugents had control of all aspects of business; 2. Control was used to commit fraud or wrong or other positive legal duty, including an “unjust act”; 3. Breach of duty caused unjust loss or injury to plaintiff Nugents were avoiding debts to plaintiffs. Refused On Top’s obligations to creditors. This is unfair, unjust and inequitable to allow Nugent to hide behind corporate shield and avoid legal obligations to plaintiffs. ©2015 Cengage Learning. All Rights Reserved. May not be scanned, copied or duplicated, or posted to a publicly accessible website, in whole or in part. TRANSFERABILITY OF OWNERSHIP INTERESTS Refers to ability of an owner in a business to sell or pass interest to others Nontraded Entities In sole proprietorship, selling the business ends the existing proprietorship. Price is FMV to be determined. If a partner sells or assigns interest in the partnership, the partnership continues, but the new person doesn’t automatically become a partner. New person is just entitled to receive the share of profits the partner would have received, But can’t participate in management of partnership or right to P-ship information without permission of other partners ©2015 Cengage Learning. All Rights Reserved. May not be scanned, copied or duplicated, or posted to a publicly accessible website, in whole or in part. DURATION Duration: Refers to ability to continue to operate in event of death, retirement or incapacity of owner of business Sole proprietorship terminates with death or incapacity of proprietor. At common law partnerships and LLC’s are dissolved by death, retirement or incapacity of a partner, but are not necessarily terminated. (Can reform) Unless, articles of incorporation provide for period of duration, corporation has perpetual existence. • Death or retirement of shareholder(s) does not bring termination of the corporation. • (In fact, usually does not have any impact on operations of the business.) ©2015 Cengage Learning. All Rights Reserved. May not be scanned, copied or duplicated, or posted to a publicly accessible website, in whole or in part. FRANCHISES Three types: 1. Product distributorships (i.e. Ford Dealership) 2. Trademark/trade-name licensing (i.e. Coca-Cola) 3. Business format franchising (i.e. McDonald’s) Franchisor grants a right to sell goods or services to a franchisee in return for payment of a franchise fee Uniform product or services and the use of a trademark help the franchisee establish quickly in the market See Exhibit 12.4 ©2015 Cengage Learning. All Rights Reserved. May not be scanned, copied or duplicated, or posted to a publicly accessible website, in whole or in part. FRANCHISES Laws are still developing Federal & state laws protect investors FTC Franchise Rule: Franchisor is required to give an offering circular (disclosure statement) to potential franchisees Some states have laws to regulate franchises as well – for example, California. o Many states have business opportunity disclosure filing requirements. o Most states use the Uniform Franchise Offering Circular (UROC) as basis of reporting. FTC v. Wealth Systems ,Inc.: FTC alleged that 3 entities violated Section 5 in selling home-based o State agencies have authority to Internet business opportunity by investigate franchise fraud and misrepresenting purchases will earn other bad business practices. substantial income. o Some franchisees given extra When violations occur, the result is protection by state laws: usually that promoted activity is closed o Example: auto dealers and gas down. stations – often have extra rights over other franchises o ©2015 Cengage Learning. All Rights Reserved. May not be scanned, copied or duplicated, or posted to a publicly accessible website, in whole or in part. FRANCHISES The franchise agreement sets forth rights and obligations of the parties, i.e. territorial rights, fees and royalties, termination, etc. Termination • Through explicit events that bring about franchise’s termination • Fixed expiration time • Franchisor’s right to termination re: occurrence of events – Inspection problems or violations of franchisee Bankruptcy of franchisor ©2015 Cengage Learning. All Rights Reserved. May not be scanned, copied or duplicated, or posted to a publicly accessible website, in whole or in part. CASE DUNKIN’ DONUTS FRANCHISED RESTAURANTS V. SANLIP o o o o o o o o Three individuals owned Sanlip, Inc, which was Dunkin’ Donuts franchisee. Operated two donut shops in Norcross Georgia Dunkin’ said defendants breached franchise agreements: Failed to remodel their shops; Failed to participate in mandatory system-wide programs; Failed to attend required training; Failed to prepare immigration forms for new employees Dunkin’ also said defendants transferred significant part of franchise w/o Dunkin’s knowledge in violation of franchise agreement. Sanlip did not dispute claims. Protested that Dunkin’ was not allowing owners reasonable chance to sell franchise. Dunkin’ entered into settlement agreement. Allowed Sanlip time to try to find buyer. (Continued) ©2015 Cengage Learning. All Rights Reserved. May not be scanned, copied or duplicated, or posted to a publicly accessible website, in whole or in part. CASE DUNKIN’ DONUTS FRANCHISED RESTAURANTS V. SANLIP Sanlip submitted proposed sale agreement. Dunkin’ refused to accept the buyer. Asked court to order Sanlip to return shops to Dunkin’. Sanlip counterclaimed: Dunkin’ had rejected a reasonable proposal from buyer to take over shop. HELD: Summary Judgment in favor of Dunkin’ Donuts. Defendants must pay attorneys’ fees & costs. Dunkin’ may not “unreasonably” reject proposed sale agreement. Dunkin’ analysis: If store will lose money. If so, Dunkin’ rejects proposed sale agreement. Also looks at financial condition of the buyer if it decides store may break even. This is firmly-established policy by Dunkin’ and reasonable. Dunkin’ has right to terminate the agreement. Lease agreements provide Dunkin’ may terminate lease if franchise agreement for shop is terminated for any reason. ©2015 Cengage Learning. All Rights Reserved. May not be scanned, copied or duplicated, or posted to a publicly accessible website, in whole or in part.