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Ask Us Anything: Startup Law with Archetype Legal

  • 1.  Ask Us Anything: Startup Law with Archetype Legal

    Posted 01-15-2025 14:02

    Hello Carta Community!

    We're attorneys from Archetype Legal PC. We serve entrepreneurs, startups, and small businesses as they grow and evolve. We believe the practice of law can be completed with a three-step approach: transparency, philanthropy, and sophistication.  We'll be here to answer your questions next Wednesday, January 22, at 11:OO AM PT. From formation to an eventual exit and everything in between, such as raising capital, equity compensation, commercial transaction, compliance, and business strategy, you can ask us anything!*

    We hope to interact with you on the 22nd. A bit more about us below -

    Alex King is the founder of Archetype Legal; he brings deep expertise in startup financing, equity structures, and commercial transactions.

    Alexis DeBose is a seasoned attorney at Archetype Legal who specializes in corporate law with expertise in entity formations and corporate compliance.

    *DISCLAIMER: This is a rapid-fire response, and our feedback and comments are intended to be high-level thoughts without evaluating things like your corporate governance documents or having an opportunity to dive below the surface and know what is going on. No one should act or refrain from acting solely on what is said in our discussion. You are STRONGLY encouraged to speak with an attorney familiar with startups who can give you professional advice.



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    Alex King
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  • 2.  RE: Ask Us Anything: Startup Law with Archetype Legal

    Posted 01-15-2025 14:25

    Very excited for you two to host this AMA! This is our first repeat host of Ask an Expert, and we're very grateful to the Archetype team for sharing their expertise with us and their continued support in Carta Community. 


    A quick word from Carta's legal team: 

    DISCLOSURE: This event is presented on behalf of eShares, Inc., dba Carta, Inc. ("Carta"). The content of this event is not, and no opinions or comments shared in this event should be treated or construed as, accounting, business, financial, investment, legal, tax, or other professional advice or services​​. This event is for information purposes only. The content of this event is not intended as a recommendation, offer or solicitation for the purchase or sale of any security. Carta does not assume any liability for reliance on the information provided herein and undertakes no obligation to update content. The opinions of the guests and host are their own and do not reflect the view of Carta or Carta's affiliates. All product names, logos, and brands are property of their respective owners in the U.S. and other countries, and are used for identification purposes only. Use of these names, logos, and brands does not imply affiliation or endorsement.



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    Brent Devey
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  • 3.  RE: Ask Us Anything: Startup Law with Archetype Legal

    This message was posted by a user wishing to remain anonymous
    Posted 01-17-2025 07:54
    This message was posted by a user wishing to remain anonymous

    I heard about the recent court ruling in Texas related to the Corporate Transparency Act and BOIR requirements. Should we still prepare to file, or is enforcement on hold? Also, do you have to include board members in filing or just owners?




  • 4.  RE: Ask Us Anything: Startup Law with Archetype Legal

    Posted 01-22-2025 11:03
    Edited by Alexis DeBose 01-22-2025 11:04

    Hello, 

    Now that we're ready to rock n' roll, we'll start with responses to this first question and go from there.

    There are currently several court challenges to the Corporate Transparency Act (CTA). I believe you are referencing the ruling based out of Texas (issued December 3, 2024), wherein a district court issued an order granting a preliminary nationwide injunction as to the enforcement of the CTA, including the Beneficial Ownership Information Report (BOIR) filing requirement for Reporting Companies. As such, Reporting Companies are not required to file a BOIR with the US Department of Treasury (DoT), however, the DOT is accepting voluntary submissions of the BOIR. 

    While it is hard to anticipate with certainty where things will land when the dust settles related to these court challenges and appeals, we do not see any "harm" in filing a voluntary submission of the BOIR with the DoT, as we do not anticipate the CTA simply "disappearing" and the information supplied is stored on a non-public database within the DoT.  Further, there have been recent court rulings in Texas issued within three (3) days of each other, which (i)  re-instated the filing requirement and (ii) vacated the ruling issued a few days prior re-instating the filing requirement. You can imagine these rulings have caused further confusion, and as such, many simply choose to file the voluntary BOIR submission to be compliant with the CTA. 

    With that said, it is important that you (and each company) use your own discernment and consult with your own legal counsel prior to making a determination on whether you will file a voluntary submission and regarding the information supplied with the submission.

    Importantly, the DoT publishes live updates regarding the reporting requirements and deadlines, and we suggest that you check the BOIR landing page (linked) for the most recent updates on the reporting requirements. If the reporting requirement is re-instated and your company fails to comply, you could be faced with a $500 penalty for each day that you are not compliant.

    Reporting Companies are required to provide information related to Beneficial Owners of the Reporting Company, which are generally those who own at least 25% of the company or who exercise substantial control over the company. A board member may qualify as a beneficial owner if such board member is a 25% owner of the company or if the board member exercises substantial control over the company (which board members typically do). This will all be facts and circumstances specific. If you have questions related to who may qualify as a Beneficial Owner, the DoT publishes helpful FAQs (linked) and a compliance guideline (linked), which will help you examine who you should include as a Beneficial Owner.



    ------------------------------
    Alexis DeBose

    alexis@archetypelegal.com
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  • 5.  RE: Ask Us Anything: Startup Law with Archetype Legal

    Posted 01-17-2025 13:02

    I am still confused about form 83B. I was told I didn't need to do one, since we formed our startup and just gave out Founder's stock. Now I am giving stock to advisors. Do they need to file the form. What happens if they didn't do it on time?



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    Del-Metri Williams
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  • 6.  RE: Ask Us Anything: Startup Law with Archetype Legal

    Posted 01-22-2025 11:08

    Hi Del-Metri,

    Quick disclaimer: we're not tax professionals, and what is said below should not be construed as tax advice, but as you might suspect, our startup clients encounter the 83(b) election as part of the incorporation process, as well as other situations in which the stock granted is subject to a vesting schedule. Here are some high-level thoughts to help guide your follow-up conversations.

    An 83(b) election must be done within 30 days of receiving the stock, and there are no exceptions for a late or improper filing. An 83(b) election is commonly done when founders receive their stock subject to a "risk of forfeiture," such as a repurchase option for all unvested stock granted to the company should the stockholder no longer be in service. Therefore, if you purchased or were granted your stock, and it's subject to a vesting schedule, it's generally thought advisable (there are definitely circumstances in which it would not be) to file an 83(b) election. 

    However, an 83(b) is generally unnecessary if your stock is fully vested. Furthermore, if the holder received a stock option grant, which does not allow for early exercise, an 83(b) is also generally unnecessary. 

    Granting stock to advisors is typically done via an "equity incentive plan" (sometimes called a Stock Plan or Stock Option Plan) and in the form of stock options without early exercise. An equity incentive plan (and a relevant state filing) is all but necessary to comply with private placement regulations for the issuance of a security to a service provider. Again, an 83b(b) is usually unnecessary for a stock option unless the recipient is subject to vesting and has the right to early exercise. However, if the advisor grant is a stock grant or a stock purchase right and there is a vesting schedule (advisable to have a vesting schedule), then an 83(b) election should be considered.

    The consequence of failing to file is that the recipient would be taxed at each vesting period based on the change in value from the sale/grant price to the new fair market value. You can avoid this with a properly filed 83(b) election, and once again, before taking any further actions, we'd encourage you to speak to a tax professional such as a CPA.

    -Alex



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    Alex King
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  • 7.  RE: Ask Us Anything: Startup Law with Archetype Legal

    This message was posted by a user wishing to remain anonymous
    Posted 01-17-2025 13:39
    This message was posted by a user wishing to remain anonymous

    We are in the process of raising money in a seed round. We are also hiring some staff in February. We have a current 409(a) valuation, but what do we do if we're in the middle of our seed round, with some written committments (and maybe even some funds received) when the new employee starts? Do we wait until the Seed Round is complete to do a 409(a) and then issue the new employee options after that? Or issue the options at the old 409(a) valuation?




  • 8.  RE: Ask Us Anything: Startup Law with Archetype Legal

    Posted 01-22-2025 11:10

    A 409A valuation is valid for one year from the valuation date unless a transaction or activity results in a "material change" in the company's valuation that would otherwise invalidate the valuation before the one-year expiration. For startups, the most common transaction that would adjust the company's price is entering into a term sheet for an equity (usually preferred stock) financing round. Thus, it's advisable to speak with a valuation expert (cautiously optimistic the Carta team can guide you), and my hunch is that their guidance will be to hold off until the seed round is completed, obtain a new 409A and issue equity awards based on the revised valuation.

    -Alex



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    Alex King
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  • 9.  RE: Ask Us Anything: Startup Law with Archetype Legal

    Posted 01-17-2025 13:44

    Which document is usually counted to be a legal proof of an LLC owning equity in a startup registered in a non-US jurisdiction? What are some general legal procedures triggered if an LLC decides to sell that stake to a third party at a later stage? Is this something to be reflected in a document that is different from the articles of incorporation of a non-US registered startup?



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    Andy Kozlov
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  • 10.  RE: Ask Us Anything: Startup Law with Archetype Legal

    Posted 01-22-2025 11:14

    Hi Andy,

    It is tough to say with any conviction because we are US attorneys unfamiliar with other countries' rules and regulations. However, generally speaking, it would be a stock certificate, stock purchase agreement, or other paperwork to evidence ownership in the foreign company. And yes, it would generally be documented outside of the Articles of Incorporation, as such a document for US purposes does not indicate who owns what in the corporation. If the foreign entity is similar to a US LLC, the ownership would be documented in the Operating Agreement and/or a Membership Interest or Unit Purchase Agreement.

    As for selling the shares to a third party, you must adhere to securities rules and regulations within this foreign entity's jurisdiction. In the US, a commonly used rule resales is Rule 144. I am cautiously optimistic that the country where the foreign entity is located will have a similar rule and procedure for allowing resales in compliance with private place rules and regulations.

    -Alex

    alex@archetypelegal.com



    ------------------------------
    Alex King
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  • 11.  RE: Ask Us Anything: Startup Law with Archetype Legal

    Posted 01-21-2025 08:59

    From a legal perspective, can one invest their own IRA funds to purchase qualified stock options in the startup to which one is employed? Does it matter if one is an officer versus a non-officer employee?
    Thanks!



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    Chad Stamper
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  • 12.  RE: Ask Us Anything: Startup Law with Archetype Legal

    Posted 01-22-2025 11:16

    Hi Chad,

    This is best addressed with the guidance of your financial advisor, as there are rules and regulations tied to IRA funds that we're unqualified to comment on with any authority. That said, it's our limited understanding that a self-directed IRA would allow you to use the funds to purchase options in a private company (and we've seen self-directed funds buy an equity interest as part of a preferred stock and other financing rounds). We're unaware of any rule variation regarding whether the option holder should be an officer versus a non-officer employee.

    -Alex

    alex@archetypelegal.com



    ------------------------------
    Alex King
    ------------------------------



  • 13.  RE: Ask Us Anything: Startup Law with Archetype Legal

    Posted 01-22-2025 09:49

    Hello! Thanks for hosting this session. My question is that I'm wondering if you all could comment on the legal liability as it relates between the securities issuer (client company using Carta software) and Carta itself in the role of transfer agent. Specifically, I'm referring to mistakes or problems when securities are issued and potential legal action from investors/stakeholders. Is Carta viewed more as a mechanical tool to issue securities and the liability is skewed towards the securities issuer?



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    Laurence Sarner
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  • 14.  RE: Ask Us Anything: Startup Law with Archetype Legal

    Posted 01-22-2025 11:18

    Hi Laurence,

    It's a good question. I found some information here, and I would encourage you to connect with a Carta's representatives if you have further questions or concerns about Carta's role as a transfer agent (we're not employed or qualified to speak on Carta's behalf). 

    I'm copying and pasting from the link above -

    eShares, Inc. DBA Carta, Inc. is a transfer agent registered with the U.S. Securities and Exchange Commission.

    The services and information described in this communication are provided to you "as is" and "as available" without warranties of any kind, expressed, implied or otherwise, including but not limited to all warranties of merchantability, fitness for a particular purpose, or non-infringement. Neither eShares, Inc. DBA Carta, Inc. nor any of its affiliates will be liable for any damages, including without limitation direct, indirect, special, punitive or consequential damages, caused in any way or arising from the use of the services or reliance upon the information provided in this communication or in connection with any failure of performance, error, omission, interruption, defect, delay in operation or transmission, computer virus or line or system failure.

    -Alex

    alex@archetypelegal.com



    ------------------------------
    Alex King
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  • 15.  RE: Ask Us Anything: Startup Law with Archetype Legal

    This message was posted by a user wishing to remain anonymous
    Posted 01-22-2025 11:11
    This message was posted by a user wishing to remain anonymous

    Thank you for your hosting. 

    2 questions for Archetype Legal:

    1. When should a startup consider patenting their technology? We are an AI-based fintech startup with some exciting breakthroughs in applying AI to finance but understand both that business methods are unpatentable and there is large cost and expense with securing a patent. When is it worth it vs. sticking with trade secrets. 2. When issuing restricted stock to the founding team, we set up some ambitious performance targets that subsequently proved overly ambitious. Our own legal team is saying that the company needs to buy back the stock incentives from the founders. We're frustrated because we wonder why then the stock needed to have been bought in the first place. Are we doing the right thing by buying back?




  • 16.  RE: Ask Us Anything: Startup Law with Archetype Legal

    Posted 01-22-2025 11:28

    We're not patent experts, however, the sooner you file and secure registered IP (e.g. trademarks, patents, copyrights, etc), the quicker you can enforce your rights as the rightful owner of such intellectual property, aiding your competitive advantage. Thus, we recommend you err on the side of acting sooner rather than later but would defer to a patent expert. We're happy to make an introduction to our go-to patent expert if that would be helpful (my contact info is below).

    On the second question, I have no reason to doubt your legal team's guidance, and without further context we'll assume they are pointing you in the right direction. A vesting schedule (whether time or milestone-based) is a tool used to ensure founders do not walk away with dead equity, as dead equity is detrimental to future growth and fundraising activities. Thus, if a founder has departed and your counsel is recommending the repurchase of an unvested portion of their shares, that makes sense to us. If the founder is still with the company, and there is a proposed buyback we'd be less confident that is sound advice without further context. Furthermore, for those founders who are still with the company, if the board of directors wishes to rethink the original vesting schedule to better align with company incentives, an adjustment to the original equity award is permissible.

    -Alex

    alex@archetypelegal.com



    ------------------------------
    Alex King
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  • 17.  RE: Ask Us Anything: Startup Law with Archetype Legal

    This message was posted by a user wishing to remain anonymous
    Posted 01-22-2025 11:12
    This message was posted by a user wishing to remain anonymous

    Hello,
    Thanks for hosting this AMA and I apologize if this is not the proper place to post questions during the AMA but I'm a bit confused with the format or where to post during the discussion.

    Anyhow, I'm in a particular situation where I had a company incorporated in Delaware and I am the CEO but I haven't launched the product yet however I am on the cusp of launching another. Is it possible to have two domains and respective businesses under the same C corp? or do I need a separate one? I know it likely would make sense in the long term to file for a separate c corp but in lieu of that could i start earning revenue through my existing one and later transfer?




  • 18.  RE: Ask Us Anything: Startup Law with Archetype Legal

    Posted 01-22-2025 11:52
    Edited by Alexis DeBose 01-22-2025 11:54

    Hello, 

    Thank you for your question! You are in the right place and are posting your question in the correct forum/format. 

    Absent statutory restrictions on the services or products you provide (e.g., some states may restrict your ability to provide licensed-professional services such as legal, medical, achitecture services under certain entity types or structures) you can certainly provide more than one line of service or product under one company.  I can certainly understand reasons why you may want to do so, but there are a number of reasons why you may not want to do so. Ultimately, a determination should be facts and circumstances based and you should consult with your personal attorney and tax advisor on the implications to make an informed decision. 

    With that said, one reason that you may want to maintain two separate entities and likely the most determinitive, is the liability aspect. Provided you follow the corporate formalities of your particular company (e.g., filing your annual reports, filing annual state and federal taxes, holding annual board and shareholder meetings, no commingling, etc.), should a plaintiff file suit against your company, such plaintiff will (generally) be limited to the assets of the company (said another way, there is a liability shield in place). When you run multiple businesses under one company, these different lines of business share liabilities, meaning if one line of business faces financial or legal challenges, the other could be implicated as well (as it is operated as "one" business"). Thus, having two distinct business entities helps keep such liabilities separate and distinct. 

    Second, revenue from both businesses (if run under one company), will be reported under the same entity. I would make sure that you are consulting with your CPA, accountant, and/or tax advisor on whether it is advisable to keep the two companies under one official company or to separate these out into two distinct entities (and whether making this decision now will make things easier than if you have to separate the financials of the businesses at a later time). 

    Third, you may also face some investor concerns over IP ownership and their investment decisions. If you seek investors for one of the lines of business and they conduct due diligence, they may prefer to keep their investment tied to one distinct entity based on the product or service line. Now, this is wholly dependent on your investor profile and whether a particular investor may actually "care" about this issue but it may come up. Further on this note, if you take on investment in the company and then you transfer certain intellectual property of the company upon making such a transition, you may have to manage investor relations that you would not otherwise have to manage if you had two distinct entities (as an investor may make the argument that they invested in the company based on Y, which you have now transferred to another company/venture). 

    There may be other reasons why keeping these businesses separate and distinct may be advantageous, and we suggest you consult with folks such as your CPA, business partners.

    In summary, absent some restriction on the type of busines you are conducting, you can certainly conduct the business affairs of two lines of businesses but you may decide that it is well worth the costs/time now to keep these lines of businesses separate and distinct with two separate entities to keep (i) liability separate and distinct and (ii) IP and ownership concerns manageable and "clean" for the owners of the company and/or investors.



    ------------------------------
    Alexis DeBose

    -alexis@archetypelegal.com
    ------------------------------



  • 19.  RE: Ask Us Anything: Startup Law with Archetype Legal

    Posted 01-22-2025 11:17

    I'm familiar with the stock incentive plans for c-corporations that provide for issuing qualified and non-qualified stock options or RSAs. Do LLCs have a comparable plan and if so what are the requirements and where might I be able to read up such plans?  Thanks



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    Chad Stamper
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  • 20.  RE: Ask Us Anything: Startup Law with Archetype Legal

    Posted 01-22-2025 11:34

    Hi Chad,

    LLCs typically use what are referred to as "profit interest", which is properly structured allows the recipient to receive the grant tax-free. Like a stock option, it allows the recipient to participate in the upside after the distribution threshold has been met. It is recommended that a "Profit Unit Plan" is put in place to align with federal Rule 701, and a benefit plan exemption is also filed with the state the LLC is headquartered. This is a helpful article outlining profit interests, and how they might be used, but it is recommended you seek the counsel of an attorney and tax advisor to ensure you understand all of the implications of adopting such a plan and granting profit interest to service providers.

    -Alex

    alex@archetypelegal.com



    ------------------------------
    Alex King
    ------------------------------



  • 21.  RE: Ask Us Anything: Startup Law with Archetype Legal

    Posted 01-22-2025 12:01

    Thank you to @Brent Devey for setting this up, and for everyone who asked a question. Should you ever need legal assistance, don't hesitate to reach out.

    Alex - alex@archetypelegal.com

    Alexis - alexis@archetypelegal.com



    ------------------------------
    Alex King
    ------------------------------