For owners
Cannabis exit planning
Federal and state law current as of September 2026 — verify with counsel.
Key takeaways
- As of September 2026, medical marijuana is Schedule III; adult-use remains Schedule I (Federal Register 2026-08176 and pending hearing).
- 280E still hits adult-use SG&A; medical books may take ordinary deductions — apportion dual licenses.
- SBA loans are unavailable for plant-touching targets (SOP 50 10 8).
- Deals close on regulatory approval; control does not move early.
- Single-store commentary multiples of about 3x–6x EBITDA are trade ranges, not appraisals (2025–2026 commentary).
Cannabis exit planning is a long-form working map for owners. Use it to sequence the file, not to skip counsel. This page is written for owners and for more than one license class. It is not legal or tax advice.
Cannabis exit planning does not create interstate adult-use commerce, SBA eligibility, or a USCIS safe harbor. Chapter 7 and 11 remain generally closed to domestic plant-touching debtors. Hemp is CRS IF13136 plus the 12 November 2026 effective date. Price the file that exists.
| Topic | Working rule (verify, September 2026) |
|---|---|
| Audience | owners |
| License lens | more than one license class |
| Contrast markets | Michigan / Ohio / Maryland |
| SBA | Unavailable for plant-touching (SOP 50 10 8) |
| Hemp clock | P.L. 119-37 redefinition 12 November 2026 |
| Commentary multiple (not an appraisal) | 4x–43x normalized earnings |
Banking after Cannabis exit planning — why does this change Cannabis exit planning?
FinCEN FIN-2014-G001 is still the SAR frame. A new owner who assumes the seller’s bank will keep the account is guessing. Model cash handling until the successor account is real.
When to walk away from Cannabis exit planning — why does this change Cannabis exit planning?
If the license is locked, the city will not host the buyer, the books cannot be rebuilt, or the hemp catalog dies in November 2026, the honest answer is stop. Cannabis exit planning is not improved by optimism.
Partner and dispute uses of Cannabis exit planning — how should you read this on Cannabis exit planning?
Buyouts and shareholder fights still need a method, not a slogan. Label ranges. Do not pretend a liquor-store rule prices Cannabis exit planning.
Inventory and biomass on Cannabis exit planning — what breaks Cannabis exit planning?
What is on the floor at close has to match the state system. Failed tests and unsold canopy are price, not atmosphere. Count it.
Real estate attached to Cannabis exit planning — how should you read this on Cannabis exit planning?
The building can be the deal or the trap. No cannabis-use clause means Cannabis exit planning cannot operate after assignment. Sale-leasebacks are capital, not magic.
Social-equity paper inside Cannabis exit planning — why does this change Cannabis exit planning?
Eligible-transferee rules and holding periods are deal terms. Cannabis exit planning that ignores them is a letter, not a close. See social-equity locks.
Distressed paths near Cannabis exit planning — what belongs on Cannabis exit planning?
Receiverships and ABCs exist because chapter 7 and 11 are generally closed to domestic plant-touching debtors. If Cannabis exit planning is already in a fiduciary process, price the claims, not last year’s CIM.
The first cut on Cannabis exit planning — what belongs on Cannabis exit planning?
Cannabis exit planning is decided before a teaser goes out. owners who start with a hoped-for multiple skip whether the paper can move. Michigan and Ohio do not share a packet. more than one license class is the lens.
Records that prove Cannabis exit planning — what belongs on Cannabis exit planning?
Rebuild Cannabis exit planning from track-and-trace, tax filings, the lease cannabis-use clause, and a cap table that matches the application. A vanity P&L is a brochure. Buyers spend after-tax cash.
Michigan habits that fail on Cannabis exit planning — what should you verify for Cannabis exit planning?
Copying a Michigan habit into Ohio is how Cannabis exit planning dies in review. Maryland is the third check. Published locks (Maryland converted control through 1 July 2028; New Jersey majority changes; California non-assignment) only apply if the premises sit there.
Cash after tax on Cannabis exit planning — how should you read this on Cannabis exit planning?
Illustrative only: $201,000 of pre-280E earnings can shrink hard on an adult-use book. Medical Schedule III relief after 28 April 2026 is a slice, not a slogan. Dual shops apportion. IRC §280E is the citation.
Capital that will not appear on Cannabis exit planning — what should you verify for Cannabis exit planning?
SBA SOP 50 10 8 still bars plant-touching 7(a) and 504. SAFE Banking Act of 2026, S.4942 is not a close condition. Cannabis exit planning is funded with seller paper, private credit, cash, or a sale-leaseback — or it is not funded.
Local authorization inside Cannabis exit planning — what belongs on Cannabis exit planning?
A state yes with a city no is a failed Cannabis exit planning. Opt-out, buffers, and CUPs are the site. Read local control before anyone argues price.
People the agency will map on Cannabis exit planning — what should you verify for Cannabis exit planning?
True parties of interest include more than the 51% owner. Silent lenders and handshake managers show up on Cannabis exit planning whether the CIM mentions them or not.
Cited sources that govern Cannabis exit planning: Hemp SKUs must be read against CRS IN12620 on the 2026 hemp definition and CRS IF13136; the redefinition date is 12 November 2026. Federal Register 2026-08176 is the April 2026 medical / FDA-approved marijuana Schedule III order. IRC §280E still disallows ordinary deductions on Schedule I trafficking, which is why adult-use books stay in 280E. FinCEN FIN-2014-G001 remains the SAR frame banks actually use.
What to bring to the intro call — what belongs on Cannabis exit planning?
Book twenty minutes with Jason Taken at HedgeStone Business Advisors. For Cannabis exit planning, bring the license class, the state, the local authorization status, and whether a buyer or target is already in the room. There is no form on this site and no invented listing book. He is a business broker, not an attorney and not a licensed cannabis operator.
Related pages for Cannabis exit planning — what should you verify for Cannabis exit planning?
Read buying guide next if that file is open on Cannabis exit planning. exit planning is the companion page when Cannabis exit planning needs that angle. Keep limited vs open in the working set for Cannabis exit planning. Read 280E statements next if that file is open on Cannabis exit planning. sell is the companion page when Cannabis exit planning needs that angle. Keep buy in the working set for Cannabis exit planning. Read valuation next if that file is open on Cannabis exit planning. selling guide is the companion page when Cannabis exit planning needs that angle.
Summary on Cannabis exit planning — how should you read this on Cannabis exit planning?
Cannabis exit planning turns on approval, after-tax cash, and the license class. Federal law current as of September 2026 is a schedule split, not a green light. Verify every rate, cap, and clock with counsel.
Which public sources belong on this file?
Read DEA diversion schedules, FDA cannabis / CBD page, IRS marijuana industry page, eCFR CSA schedules alongside the agency packet. A forum post is not a substitute.
How should you underwrite Cannabis exit planning?
Cannabis exit planning has to discount as a license-and-tax file. In New Jersey, scarcity can dominate. In Missouri, paper value can be near zero. Cited sources that govern Cannabis exit planning: Hemp SKUs must be read against CRS IN12620 on the 2026 hemp definition and CRS IF13136; the redefinition date is 12 November 2026. Federal Register 2026-08176 is the April 2026 medical / FDA-approved marijuana Schedule III order. IRC §280E still disallows ordinary deductions on Schedule I trafficking, which is why adult-use books stay in 280E. FinCEN FIN-2014-G001 remains the SAR frame banks actually use.
| Check | New Jersey | Missouri |
|---|---|---|
| Transfer / host | Verify agency | Verify city |
| Tax / 280E mix | Medical slice | Adult-use slice |
What does a 280E-literate CPA ask?
Cannabis exit planning has to haircut as a license-and-tax file. In Maryland, scarcity can dominate. In Nevada, paper value can be near zero. Cited sources that govern Cannabis exit planning: Federal Register 2026-08176 is the April 2026 medical / FDA-approved marijuana Schedule III order. IRC §280E still disallows ordinary deductions on Schedule I trafficking, which is why adult-use books stay in 280E. FinCEN FIN-2014-G001 remains the SAR frame banks actually use. SBA SOP 50 10 8 keeps plant-touching targets out of 7(a) and 504, including medical.
| Check | Maryland | Nevada |
|---|---|---|
| Transfer / host | Verify agency | Verify city |
| Tax / 280E mix | Medical slice | Adult-use slice |
How should approval be sequenced?
Cannabis exit planning has to clear as a license-and-tax file. In Massachusetts, scarcity can dominate. In Washington, paper value can be near zero. Cited sources that govern Cannabis exit planning: IRC §280E still disallows ordinary deductions on Schedule I trafficking, which is why adult-use books stay in 280E. FinCEN FIN-2014-G001 remains the SAR frame banks actually use. SBA SOP 50 10 8 keeps plant-touching targets out of 7(a) and 504, including medical. SAFE Banking Act of 2026, S.4942 and H.R.9471 were introduced in 2026 and are not law.
| Check | Massachusetts | Washington |
|---|---|---|
| Transfer / host | Verify agency | Verify city |
| Tax / 280E mix | Medical slice | Adult-use slice |
Where does the file break in Arizona versus Oregon?
Cannabis exit planning has to condition as a license-and-tax file. In Arizona, scarcity can dominate. In Oregon, paper value can be near zero. Cited sources that govern Cannabis exit planning: FinCEN FIN-2014-G001 remains the SAR frame banks actually use. SBA SOP 50 10 8 keeps plant-touching targets out of 7(a) and 504, including medical. SAFE Banking Act of 2026, S.4942 and H.R.9471 were introduced in 2026 and are not law. Hemp SKUs must be read against CRS IN12620 on the 2026 hemp definition and CRS IF13136; the redefinition date is 12 November 2026.
| Check | Arizona | Oregon |
|---|---|---|
| Transfer / host | Verify agency | Verify city |
| Tax / 280E mix | Medical slice | Adult-use slice |
What will Jason Taken not promise?
Cannabis exit planning has to apportion as a license-and-tax file. In Illinois, scarcity can dominate. In Minnesota, paper value can be near zero. Cited sources that govern Cannabis exit planning: IRC §280E still disallows ordinary deductions on Schedule I trafficking, which is why adult-use books stay in 280E. FinCEN FIN-2014-G001 remains the SAR frame banks actually use. SBA SOP 50 10 8 keeps plant-touching targets out of 7(a) and 504, including medical. SAFE Banking Act of 2026, S.4942 and H.R.9471 were introduced in 2026 and are not law.
| Check | Illinois | Minnesota |
|---|---|---|
| Transfer / host | Verify agency | Verify city |
| Tax / 280E mix | Medical slice | Adult-use slice |
How should you underwrite Cannabis exit planning?
Cannabis exit planning has to reconcile as a license-and-tax file. In California, scarcity can dominate. In Pennsylvania, paper value can be near zero. Cited sources that govern Cannabis exit planning: FinCEN FIN-2014-G001 remains the SAR frame banks actually use. SBA SOP 50 10 8 keeps plant-touching targets out of 7(a) and 504, including medical. SAFE Banking Act of 2026, S.4942 and H.R.9471 were introduced in 2026 and are not law. Hemp SKUs must be read against CRS IN12620 on the 2026 hemp definition and CRS IF13136; the redefinition date is 12 November 2026.
| Check | California | Pennsylvania |
|---|---|---|
| Transfer / host | Verify agency | Verify city |
| Tax / 280E mix | Medical slice | Adult-use slice |
What does a 280E-literate CPA ask?
Cannabis exit planning has to stage as a license-and-tax file. In Colorado, scarcity can dominate. In Connecticut, paper value can be near zero. Cited sources that govern Cannabis exit planning: SBA SOP 50 10 8 keeps plant-touching targets out of 7(a) and 504, including medical. SAFE Banking Act of 2026, S.4942 and H.R.9471 were introduced in 2026 and are not law. Hemp SKUs must be read against CRS IN12620 on the 2026 hemp definition and CRS IF13136; the redefinition date is 12 November 2026. Federal Register 2026-08176 is the April 2026 medical / FDA-approved marijuana Schedule III order.
| Check | Colorado | Connecticut |
|---|---|---|
| Transfer / host | Verify agency | Verify city |
| Tax / 280E mix | Medical slice | Adult-use slice |
How should approval be sequenced?
Cannabis exit planning has to underwrite as a license-and-tax file. In Michigan, scarcity can dominate. In Ohio, paper value can be near zero. Cited sources that govern Cannabis exit planning: SAFE Banking Act of 2026, S.4942 and H.R.9471 were introduced in 2026 and are not law. Hemp SKUs must be read against CRS IN12620 on the 2026 hemp definition and CRS IF13136; the redefinition date is 12 November 2026. Federal Register 2026-08176 is the April 2026 medical / FDA-approved marijuana Schedule III order. IRC §280E still disallows ordinary deductions on Schedule I trafficking, which is why adult-use books stay in 280E.
| Check | Michigan | Ohio |
|---|---|---|
| Transfer / host | Verify agency | Verify city |
| Tax / 280E mix | Medical slice | Adult-use slice |
Frequently asked questions
Can control move before approval?
Not if you want to keep the license. Stage closing and keep any MSA inside what the statute allows. Cannabis exit planning is still an agency event.
Will SBA finance a plant-touching purchase?
No. [SBA SOP 50 10 8](https://www.sba.gov/document/sop-50-10-lender-development-company-loan-programs) treats plant-touching marijuana businesses as ineligible for 7(a) and 504, including medical. Cannabis exit planning needs another stack.
What does HedgeStone actually do here?
Eligibility pre-screen, confidential match, METRC-aware pricing, and an approval-contingent process. Not a guaranteed price or a guaranteed yes. That is the job on Cannabis exit planning.
Is this legal or tax advice?
No. Educational only. Use cannabis-specialized counsel and a 280E-literate CPA. Jason Taken is a business broker, not an attorney and not a licensed operator.
Which records actually prove the story?
Track-and-trace, tax filings, the lease cannabis-use clause, and a cap table that matches the application. A vanity P&L is a brochure when you are underwriting Cannabis exit planning.
Who should not attempt this?
A buyer who cannot pass background or residency. An owner inside a holding period. A non-citizen who has not spoken to immigration counsel. Stop before marketing Cannabis exit planning.
Sources
- FinCEN FIN-2014-G001 — BSA expectations for marijuana-related businesses — https://www.fincen.gov/resources/statutes-regulations/guidance/bsa-expectations-regarding-marijuana-related-businesses
- SBA SOP 50 10 8 (effective 1 June 2025) — marijuana ineligibility — https://www.sba.gov/document/sop-50-10-lender-development-company-loan-programs
- Congress.gov S.4942 — SAFE Banking Act of 2026 (introduced, not enacted) — https://www.congress.gov/bill/119th-congress/senate-bill/4942
- Congress.gov H.R.9471 — companion SAFE Banking bill — https://www.congress.gov/bill/119th-congress/house-bill/9471
- CRS IF13136 / IN12620 — hemp definition change effective 12 November 2026 (P.L. 119-37) — https://www.congress.gov/crs-product/IN12620
- DEA diversion schedules — https://www.deadiversion.usdoj.gov/schedules/
- FDA cannabis and CBD page — https://www.fda.gov/news-events/public-health-focus/fda-regulation-cannabis-and-cannabis-derived-products-including-cannabidiol-cbd
- IRS marijuana industry — https://www.irs.gov/businesses/small-businesses-self-employed/marijuana-industry
- Federal Register 2026-08176 (28 April 2026) — medical / FDA-approved marijuana to Schedule III — https://www.federalregister.gov/d/2026-08176
- IRC §280E — https://www.law.cornell.edu/uscode/text/26/280E
- Viridian Capital public commentary — Tier 1 U.S. MSO EV/EBITDA ~4.16x (2025 consensus)