Cannabis Tax Strategy: Section 280E + IRC 471(c) Mastery
The definitive practitioner guide to navigating federal tax law in a Schedule I industry
Robert Hoban, Esq.
Cannabis Law Counsel — Hoban Law Group
What you will learn
- ✓Explain the statutory basis and legislative history of Section 280E
- ✓Calculate COGS expansion under IRC 471(c) for cannabis operators
- ✓Identify qualifying separate trade or business arguments
- ✓Structure client advisory memos on 280E exposure
- ✓Advise clients on rescheduling transition implications for federal tax
Course Content — 5 Modules
Module content unlocks after purchase.
280E Foundations: Statutory Text, Legislative History, and IRS Position
A deep reading of IRC § 280E from the 1982 Nedrow decision forward. Covers congressional intent, IRS Chief Counsel memoranda, and the Tax Court's evolving jurisprudence.
IRC 471(c): Inventory Cost Allocation as the Primary COGS Defense
Practitioners' guide to deploying IRC 471(c) to maximize deductible cost of goods sold — the most powerful 280E mitigation tool available today.
Separate Trade or Business: Planning, Structuring, and Litigation Risk
Analysis of the CHAMP strategy — splitting ancillary services from trafficking — including post-Harborside risk assessment and structuring requirements.
IRS Examination Defense: Audit Strategies and Settlement Positioning
Practical advocacy tools for representing cannabis clients in IRS examination — from IDR responses to Appeals and Tax Court.
Rescheduling Transition: Strategic Positioning for the Post-280E Landscape
Forward-looking analysis of DEA rescheduling proceedings, the 280E sunset trigger, and how to advise clients through the transition window.
$199
1.5 general CLE
Monitor subscribers: 20% off applied at checkout.
- ✓Lifetime access to course materials
- ✓5 video lessons + quiz
- ✓Downloadable CLE certificate
- ✓1.5 CLE credits
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