Last week, three of our California cannabis attorneys gave a one hour presentation on California’s Medicinal and Adult Use Cannabis Regulation and Safety Act (“MAUCRSA”). Topics discussed included vertical integration, multiple license ownership, major changes between the MAUCRSA and the MCRSA, and what license applicants can expect as rulemaking continues. Though more than 1500 of you signed up, we also received a large number of requests to post it on our blog from many who could not attend, and we do so now, below.

You can also find the handout we distributed during the webinar here.

Enjoy!

California cannabis events
California cannabis events. So far, so good.

In case you missed it, on June 27, 2017, California Governor Jerry Brown signed into law the Medicinal and Adult Use Cannabis Regulation and Safety Act (“MAUCRSA”). MAUCRSA repealed the Medical Cannabis Regulation Safety and Safety Act (“MCRSA”) while consolidating some of the MCRSA’s provisions with the licensing provisions of the Adult Use of Marijuana Act (“AUMA”). Our firm just recently held a webinar on the major changes between the MCRSA and MAUCRSA and what California cannabis businesses can expect from California’s Bureau of Cannabis Control (be sure to check in regularly as we’ll be posting the webinar on our site in the next couple of days). During the webinar we addressed a whole host of questions but due to the number of attendees (nearly 1,500 of you signed up) and the volume of questions, we couldn’t get to all of them. Fret not though my friends, as over the coming days we’ll be answering many of your questions here on the Canna Law Blog. As a matter of fact, how about I start now and discuss a topic on which we received a lot of questions: onsite consumption at cannabis events (where such events have slowly started to fade because of robust state cannabis regulations–see here and here).

The AUMA granted local jurisdictions the authority to decide whether smoking, vaporizing, and ingesting cannabis would be allowed by a retailer or a microbusiness. Ultimately, the ability to provide a unique and personal experience via onsite consumption will enhance California cannabis retailers and microbusinesses abilities to differentiate themselves in the marketplace. Onsite consumption will also prove to be a big advantage for California cannabis businesses bordering Nevada, as state regulators there grapple with the issue of onsite consumption.

The MAUCRSA also built on the AUMA’s concept of onsite consumption by allowing for temporary event licenses for onsite cannabis sales and consumption at district agricultural association events and your local county fair–just when you thought churros couldn’t get any better! Does that sound too good to be true? Well that’s because I haven’t mentioned the following caveats:

  • Only a licensee can receive the temporary event license;
  • Your local jurisdiction has to authorize such events in the first place;
  • Access to the area where cannabis consumption is allowed is restricted to persons 21 years of age and older;
  • Cannabis consumption is not visible from any public place or nonage-restricted area; and
  • Sale or consumption of alcohol or tobacco is not allowed on the premises. Sorry, but no jamming out to Phish with a beer and a pre-roll in your future.

The MAUCRSA also states the activities at such events must be “otherwise consistent with regulations promulgated and adopted by the Bureau [of Cannabis Control] governing state temporary event licenses.” What are these regulations you ask? Unfortunately we won’t know until the Bureau releases them in the fall. Normally we’d look to the draft medical regulations the Bureau released this past April for guidance but those regulations didn’t cover onsite consumption and they only apply to MCRSA (and have been withdrawn because of MAUCRSA). What we do know is there’s a lot of interest in how the Bureau will interpret the definition of premises. Premises is currently defined in the MAUCRSA as follows:

The designated structure or structures and land specified in the application that is owned, leased, or otherwise held under the control of the applicant or licensee where the commercial cannabis activity will be or is conducted. The premises shall be a contiguous area and shall only be occupied by one licensee.

If the area “held under the control of the applicant and licensee” is separate and distinct from the rest of the fairground, will that constitute separate premises and satisfy the alcohol restriction? At most county fairs you’ll find a great selection of local wines and craft beers and that’s not going to be changing any time soon. However we foresee county fairs will not want to miss out on the revenue and foot traffic a well-cultivated list (pun definitely intended) of cannabis businesses can attract.

Will the Bureau propose reasonable regulations (perhaps restricting cannabis consumption to evening hours?) to allow county fairs to provide for reasonable consumption of alcohol and cannabis on county fairgrounds? Will the one licensee restriction apply to temporary events? That seems unlikely, but until the State of California releases its cannabis regulations we won’t know for certain. What we do know is that these temporary event licenses will be a great way for entrepreneurial cannabis businesses to market themselves – let’s just hope the Bureau issues business friendly and reasonable regulations.

 

When Bernie Sanders announced he was in favor of removing marijuana from any schedule in the Controlled Substances Act, it was a big deal. He was the first serious presidential candidate in either a general election or a primary to take such a forward-looking stance, and it at least temporarily brought the issue of cannabis legalization to the front of voters’ minds. In the general election, of course, neither Hillary Clinton nor Donald Trump supported legalization. Clinton’s position was to do more research and otherwise leave it to the states, while Trump waffled between supporting medical marijuana, to leaving it to the states, to outright hostility.

When 2020 rolls around, however, it is becoming increasingly likely that whomever the Democrats nominate will be vocally in favor of legalization. Less than a year into President Trump’s term, Democratic senators are already moving to position themselves as the party’s next nominee. And, as reported in Politico, those candidates are increasingly moving in the direction of legalization. Senator Kamala Harris of California, a former prosecutor and state Attorney General, has voiced support for decriminalization. Senator Kirsten Gillibrand of New York has vocally supported various medical marijuana bills in the past few years. Finally, Senator Cory Booker of New Jersey has gone so far as to introduce a bill fully legalizing marijuana at the federal level. Booker’s bill would deschedule marijuana, retroactively expunge the criminal records of those convicted of federal marijuana possession or use charges, and withhold federal law enforcement dollars from states with arrest rates and incarceration rates for marijuana crimes that skew heavily against poor people and racial minorities. Unfortunately, Booker’s bill has no chance of passing or even being debated while Republicans hold the House, the Senate, and the White House. But it does draw a clear line in the sand for all would-be 2020 contenders on the Democratic side.

The real story here is that the Democratic Party is getting to the point where it must support legalization to stay relevant. There seem to be three types of Democratic politician right now: Sanders-style social-democrats, Clinton-style Baby Boomer liberals, and Booker/Harris/Gillibrand style young liberals. There are a few centrist/conservative Democrats still out there (e.g. Joe Manchin of West Virginia), but most of the rest of the party falls largely into one of the other alignments. The difference between the Clinton group and the Booker group isn’t based so much on policy as it is on candidate age and priorities. Baby Boomers (people born between the mid-1940s and the early 1960s) were the generation most influenced and susceptible to the War on Drugs. For as long as the Boomers have made up the core of the Democratic party, the party has been unwilling to move strongly in support of marijuana legalization. But we are now seeing a shift in the political landscape. White working class voters were up for grabs in the past, but that demographic seems to be moving toward the Republican party in droves. For Democrats to survive, they need to pull stronger numbers from their core demographics, including minorities disproportionately affected by the War on Drugs and millennials who never understand why marijuana was demonized, groups that overwhelmingly support cannabis legalization.

President Trump has always been shifty on policy, but his ardently anti-cannabis Attorney General, Jeff Sessions, presents an easy foil for pro-legalization Democrats to compare themselves to. Other than exceptions like Rand Paul and Dana Rohrabacher, the Republican party remains generally anti-marijuana. And marijuana legalization is the kind of simple, understandable policy that Democratic politicians should point to as positive differentiators from their competitors. If Republicans start to see their stance against marijuana as a political liability, they too will start shifting in large numbers. Looking forward to 2018 and 2020, it is becoming increasingly clear that cannabis legalization will be both good policy and good politics.

Cannabis taxesThe United States Court of Appeals for the Ninth Circuit recently ruled on its second tax case regarding IRC §280E.  Decisions from the Ninth Circuit are significant as they apply to the cannabis-friendly states of Alaska, California, Nevada, Oregon; and Washington. In Canna Care vs. the Commissioner, the Court of Appeals upheld the United States Tax Court’s ruling denying a California dispensary’s operating expense deductions under IRC §280E.

Background

Canna Care Inc. was a medical marijuana dispensary prohibited under California law from earning a profit on the sale of cannabis.  On audit, the IRS applied IRC §280E to deny the deduction of all operating expenses, including substantial officer’s salaries and automobile expenses. Canna Care appealed the tax assessment to the U.S. Tax Court. Canna Care made the following three arguments before the U.S. Tax Court:

  • That medical marijuana is not a Schedule I controlled substance;
  • That Canna Care was not “trafficking” for purposes of IRC §280E because its activities were not illegal under the California Compassionate Use Act of 1996;
  • That the Tax Court decision in CHAMP was incorrect.

The Tax Court denied all three arguments and upheld the tax assessment against Canna Care. First the Tax Court reiterated that medical marijuana is a Schedule I controlled substance. Second, the Tax Court held that the sale of medical marijuana is always considered trafficking under IRC §280E, even when permitted by state law. Thus, operating expenses associated with the sale, manufacturing or production of cannabis are always disallowed under IRC §280E.

Third, the Tax Court held that the CHAMP had been correctly decided. Canna Care’s argument that its sole business was providing charitable work like the taxpayer in CHAMP was without merit. The Tax Court held that because Canna Care’s only business was selling cannabis, none of its operating expenses could be deducted under IRC §280E. The Tax Court noted that Canna Care arguably had a second trade or business selling clothing and could have argued these expenses should be deducted. As that fact was not stipulated in its petition, the Tax Court could not consider that issue on the merits.

Appeal to the Ninth Circuit Court of Appeals 

Canna Care appealed to the Ninth Circuit Court of Appeals. None of the arguments before the Tax Court were made on appeal.  Instead, Canna Care raised three new arguments, two of which were unique to Canna Care’s facts and likely not applicable to most other cannabis businesses.

Canna Care’s primary argument was that IRC §280E violates the Excessive Fine Clause of the 8th Amendment of the United States Constitution. In oral argument before the Ninth Circuit Court of Appeals, Canna Care argued that IRC §280E was enacted by Congress to punish drug dealers, and as such, it imposes a fine on cannabis dispensaries. Canna Care noted that its income tax liability was 1000% of its net income and a 1000% tax rate for engaging in an activity allowed under California law constituted a grossly disproportionate fine on such activity. The tax rate impact under IRC §280E is especially disproportionate when compared to the tax rate of other business – both legal and illegal. Accordingly, Canna Care’s income tax liability imposed under IRC §280E constitutes an excessive fine in violation of the 8th Amendment.

In oral argument, the three-judge panel offered several observations:

  • A tax deduction is granted by the legislative grace of Congress. Congress has clear constitutional authority to deny a tax deduction. Why is IRC §280E outside Congress’ legislative authority?
  • IRC §280E was enacted in 1982, well before enactment of the California Compassionate Use Act of 1996. This means that anyone getting into the cannabis industry was and is on notice of its the burdensome tax liabilities cannabis companies face.  Given such notice, why does application of IRC §280E constitute an excessive fine under the 8th Amendment?
  • Why isn’t Congress the appropriate branch of government to address IRC §280E?

The Ninth Circuit Court of Appeals dismissed Canna Care’s appeal and upheld the Tax Court’s holding. Because the arguments presented were not raised in the lower court, The Court did not address the merits of each argument.

Assess Risk & Preserve Refund Claims

When filing their tax return, a cannabis businesses must understand the impact IRC §280E has on its tax liability. Equally important, cannabis businesses must understand the risk of not applying IRC §280E when filing their tax return. The immediate tax savings must be weighed against the risks and the costs of later having to defend the position in court.

Though it is difficult to challenge federal statutes on constitutional grounds, the constitutional arguments do have some merit. A cannabis business that challenges an IRS assessment under IRC §280E should raise all arguments early in the process to prevent a court from later dismissing arguments on procedural grounds.

Because the Ninth Circuit Court of Appeals did not rule on the merits of the 8th Amendment claim. it is possible a federal court could some day rule that IRC §280E is unconstitutional. To preserve a potential refund claim, all cannabis businesses should consider filing protective refund claims. A protective refund claim keeps the refund statute of limitation open beyond the standard three-year period. After October 15, 2017, a cannabis business cannot recover tax paid for tax year 2013. However, if a court were to hold after October 15, 2017 that IRC §280E is unconstitutional, a cannabis business that filed a 2013 protective refund claim can recover its taxes paid for that year.

It is likely more cases will be filed challenging IRC §280E.  A cannabis business should take stock of its current tax return filings applying IRC §280E and craft a strategy to defend its position.

Marijuana or cannabis

Neil deGrasse Tyson’s quote — as one would expect — is extremely rational. There is no reason for cannabis to be illegal now, nor for it to have been made illegal in the first place. As deGrasse Tyson points out, alcohol is legal and it has more known health detriments than cannabis. Similarly, tobacco is legal, and that too is more detrimental to one’s health than cannabis. Keeping cannabis illegal is irrational and unscientific. We are not calling for prohibiting alcohol or cigarettes. We are here though to use them as a basis for legalizing cannabis.

And if a great scientist sees the rationality in that, are we off base in wondering why our government cannot?

 

Cannabis lawyers
Jeff Sessions: Titling at Marijuana Windmills

On Monday, the National Conference of State Legislatures (NCSL) adopted a formal resolution that Congress enable financial institutions to serve marijuana businesses. The most interesting thing about the resolution was its forcefulness: it did not ask Congress to pass a banking bill specific to cannabis, or even to revisit the FinCEN guidelines for financial services. Instead, NCSL cut to the heart of the issue, telling Congress to deschedule marijuana altogether.

NCSL is a big deal. The bi-partisan organization represents all state legislators and their staffers nationwide. And NCSL seems to get more progressive on cannabis policy with each passing year. Last year, for example, NCSL issued a resolution that marijuana be removed from Schedule I, but not descheduled entirely. Next session, NCSL may adopt a separate resolution calling on Congress to “make medical cannabis policy a national priority to expand access to affordable medicine.” That resolution is rooted in fighting opioid addiction.

The timing of the NCSL action is important. We know that recently, Attorney General Jeff Sessions received recommendations on marijuana enforcement policy from a Justice Department task force. Sessions is keeping those recommendations under wraps, probably because they provided him with nothing to support his enforcement animus (a finding confirmed on Friday by an Associated Press report). At this point, it’s clear that Sessions is on a quixotic, lonely mission, when it comes to the issue of cannabis.

Still, Sessions is not throwing in the towel. After failing to convince Congress to allocate funds for the prosecution of medical marijuana operators two weeks ago, Sessions wrote the governors of a number of states with “serious questions” about their state cannabis programs. This letter was sent while federal agency representatives held veiled meetings about marijuana policy with state and local officials in Colorado. What exactly those meetings covered has not been ascertained. We do know, however, that Sessions has been using bogus weed statistics in the hopes of furthering his aims.

With Sessions working around the edges to promote his retrograde War on Drugs agenda, it is heartening to see legislative groups like NCSL proclaim that states are having none of it. Going forward, states will continue to set the trend on cannabis legalization, although Congress may find itself having to act sooner rather than later to re- or deschedule marijuana. Ironically, the catalyst for that action may be Attorney General Sessions, who continues tilting at windmills in his own strange reality.

Washington State Cannabis LawyersThe Washington State Liquor and Cannabis Board (LCB) yesterday rescinded its interim policy prohibiting a business or individual from owning multiple cannabis producer licenses. Now, a business and its principals can own up to three cannabis production licenses, which is up from just one license.

Though the LCB’s own rules (WAC 314-55-075) state that “any entity and/or principals within any entity are limited to no more than three marijuana producer licenses,” as of 2014, it restricted cannabis producers to no more than one producer license. Our Washington State cannabis lawyers never liked that restriction as we thought it encouraged illegal grows and bad behavior. See Washington LCB Producer License Roll-Back May Encourage Black Market Growers

The LCB announced its decision to rescind its one producer license policy at yesterday’s LCB meeting and noting how Washington State cannabis producers had been pushing to be able to expand and how the LCB’s own rules (WAC 314-55-075) allow ownership of up to three producer licenses. The LCB said it was time for the Board to “get out of the way” of Washington State cannabis producers.
We wholeheartedly agree.

To be clear, this shift in LCB policy towards producer licenses does not mean the LCB will be accepting new producer applications or expanding canopy space for existing producers; the LCB will not issue producer licenses to any new applicants nor will its policies on canopy space change. What this announcement does mean though — and this is a big deal — is that anyone who already holds a Washington State producer’s license will now be free to expand its cannabis production capabilities and canopy by purchasing other licensed producer businesses (up to two more). We know there is a massive pent-up demand for such purchases and sales because hardly a week goes by without one of our Washington State cannabis producer clients telling us of their desire to expand their production operations (mostly to better achieve economies of scale), and we also get frequent calls from companies (and clients) wanting to sell their production operations.

What we predict will happen in the market is a massive consolidation of smaller and/or struggling cultivators who will sell their businesses to larger-scale producers that are well organized and well capitalized. For years we have suspected this market consolidation of cannabis producers would occur in Washington and we see it likely to happen in other states as well.

If you are contemplating buying or selling a Washington cannabis production business/license you should be sure to check out the following:

 

 

Cannabis lawyersPresident Trump spent some time attacking Jeff Sessions on Twitter in July. There are plenty of reasons why that was a bad thing. You don’t want the leader of the executive branch attacking the chief law enforcement officer in the nation for failing to stand in the way of an investigation into that leader. But if you temporarily ignore the threats to democracy, it was pretty fun watching Sessions get metaphorically slapped around. Mr. “Good people don’t smoke marijuana” was only able to come back with a lame comment that Trump’s behavior was “kind of hurtful” while still calling him a “strong leader.” Show some backbone.

Despite the attacks, it looks like Sessions is sticking around, which means we have to continue guessing how his Department of Justice is going to treat marijuana. On that front, there is some bad news and some potentially good news.

On the negative front, the Huffington Post uncovered a letter Sessions sent to Washington Governor Jay Inslee on July 24. In that letter, which was in response to various requests to Sessions from Inslee and others that Sessions reaffirm the validity of the Cole Memo, Sessions does not deviate from the Cole Memo. Instead, he cherry picks data and presents statistics in a way that negatively reflects on Washington’s marijuana regulatory system. The vast majority of his criticisms are unfair or are outright misleading.

This post isn’t a good place to refute each of his arguments, but here are some of the highlights. He states that Washington’s medical marijuana system is considered “grey” due to a lack of regulation. But his information dates back to 2014 — Washington folded medical marijuana into its regulated system in 2015. He claims that 90% of the “public safety violations” that occur in Washington involve minors. But this is because Washington groups its violations into four categories, and all violations involving minors are in the “public safety” category. Other violations that are more common are in other categories. Additionally, a percentage without any reference to the whole is meaningless — referring to the 90% without reference to the whole is purposefully misleading. Finally, he stupidly claims Washington State isn’t well regulated because the leading regulatory violation is “failure to utilize and/or maintain traceability.” If the state is policing traceability so much that it is consistently nailing businesses for any deviation from the law, that is the definition of robustly regulating an industry. Regulatory enforcement isn’t evidence of a lack of regulation — it is the opposite.

My firm’s cannabis lawyers have since 2010 represented clients all over the country, and from this I can tell you that Washington State tends to have the toughest regulations and the strictest enforcement. The idea that Washington isn’t robustly regulating the cannabis industry is laughable. If Jeff Sessions wants to attack the principles of the Cole Memo, he should just do it instead of hiding behind weak accusations that Washington is violating its tenets.

But this is where the potential good news comes in, or at least a reason why Sessions is trying to couch his arguments within the terms of the Cole Memo. Sitting on Sessions’s desk right now is a report from his own Task Force on Crime Reduction and Public Safety. The Department of Justice hasn’t released that report, but the Associated Press got a copy of it, and contrary to expectations, the Task Force does not recommend any changes to current DOJ policy in the Cole Memo. That makes sense of course. Even if you hate marijuana, the Department of Justice doesn’t have an unlimited budget. Every penny and every man-hour dedicated to marijuana is taken away from opioids, terrorism, violent crime, etc. If the states are not acting as partners in federal law enforcement, why would the feds use resources to target marijuana businesses and their customers in those states?

But no matter what policy the Department of Justice ends up pursuing, Sessions will never back down on the marijuana rhetoric. “Drugs are bad” are ingrained in his identity, as they have been in every hippie-hating conservative politician since Nixon. Marijuana usage, homosexuality, and alternative lifestyles that are indicative of someone being an “other” are anathema to the Sessions dream of Americana. But as demographics and polling show us, there are a lot more of us than there are of him.

California cannabis distribution lawUnder California’s now-repealed Medical Cannabis Regulation and Safety Act (“MCRSA”), would-be distributors would have had a field day (which became the subject of great debate industry wide). Under the MCRSA, California’s cannabis cultivators and manufacturers would have had to sell their products to licensed distributors who would then sell those products to licensed retailers. MCRSA distributors had to be separately owned from other licensees and the MCRSA draft rules mandated that distributors take title to all product. All of that has changed with passage of the Medicinal and Adult Use Cannabis Regulation and Safety Act (a/k/a MAUCRSA, SB 94, or the Governor’s Budget Trailer Bill), which combines medical and adult use cannabis laws and rules, repeals the MCRSA, and forces withdrawal of the MCRSA draft rules.

Under MAUCRSA, cannabis licensees can vertically integrate and even act as their own distributor. This ultimately means California cannabis distributors won’t really act as distributors as we know them from the alcohol model. Instead, cannabis distributors will mostly help transport product and be the arbiters of product quality assurance.

Under the common three-tier system of alcohol distribution in the U.S., you have three main actors: importers or producers, distributors, and retailers. Essentially, producers (brewers, winemakers, importers, etc.) sell their products only to wholesale distributors who then sell to retailers (bars, liquor stores, grocery stores, etc.). Only retailers can sell to consumers. The alcohol distributor is crucial to the distribution chain and therefore immensely powerful. The distributor is solely responsible for setting up the relationship between retailers and producers and it does this by negotiating prices and providing brand selection between the two. Why have this three tier model? The main reasons for doing this in the alcohol industry were to limit consumer overconsumption with high taxes (you have more taxable events by having a middle man) and by giving profit access to more players.

California’s version of a cannabis distributor under MAUCRSA seems to have all of the obligations of an alcohol distributor but not really any of the benefits of exclusivity or control between licensees. MAUCRSA defines “distribution” as the procurement, sale, and transport of cannabis and cannabis products between licensees. As of now, distributors are the only licensees that can transport inventory between licensees and the only licensees that must make sure third-party testing is completed and that all product packaging and labeling meet state requirements. Interestingly though, cannabis licensees are not required to sell their cannabis or cannabis products to a distributor and may directly sell to any licensee authorized to sell cannabis and cannabis products to purchasers. Despite this, all cultivation and manufacturing licensees must go through a distributor for testing and packaging and labeling quality assurance and distributors can charge fees for these services. Distributors will also be the ones to collect and remit taxes on behalf of cultivators and retailers and they must secure a Board of Equalization permit (in addition to state licensing) to do so.

Under the MCRSA, it seemed existing alcohol distributors and those acting like distributors under Prop. 215’s medical cannabis collective model were well-positioned to become power players in California’s cannabis industry. But now with passage of the MAUCRSA, it’s likely California will issue a slew of cannabis distributor licenses to actors of all sizes and these distributers will become one-stop-shops for mandatory quality assurance and little more. If California wants to avoid the same sort of distribution problems that befell Nevada in the early days of its adult use sales, it will need to issue a large number of distributor licenses. There may end up being some market for a distribution only model (in the alcohol sense) for distributors that can help their cultivator and manufacturer customers expand their markets and gain market share or that can help retailers secure top quality products and brands at good prices. But now that it will be so easy for cultivators, manufacturers, and retailers to get around distributors to forge their own relationships with each other, the role of cannabis distributors in California is far from the alcohol model.

To help you better understand what is going on with California cannabis and what MAUCRSA means for your cannabis business, three of our California attorneys will be hosting a free webinar on Tuesday August 8, 2017, from 12 pm to 1 pm PT. From our Los Angeles office, I will be moderating two of our San Francisco-based attorneys (Alison Malsbury and Habib Bentelab) in a discussion on the major changes between the MCRSA and the MAUCRSA, including on vertical integration and ownership of multiple licenses, revised distributorship standards, and what California cannabis license applicants can expect more generally from California’s Bureau of Cannabis Control as rulemaking continues through the remainder of the year. We will also address questions from the audience both during and at the end of the webinar.

To register for this free webinar, please click here. We look forward to your joining us.

California Cannabis rules

Sign up now for TODAY’s free webinar on California’s Medical and Adult Use Cannabis Regulation and Safety Act (“MAUCRSA”), which will take place from 12-1 pm Pacific. MAUCRSA, which effectively repealed the Medical Cannabis Regulation and Safety Act (“MCRSA”), combines both medical and recreational cannabis into one regulatory scheme. Presented by Hilary Bricken, Alison Malsbury, and Habib Bentaleb (three of our cannabis lawyers who work out of our offices in Los Angeles and San Francisco), this webinar will address what this new legislation means for your California cannabis business. The attorneys will discuss:

  • Vertical integration
  • Ownership of multiple licenses
  • Distributorship
  • Major changes between MAUCRSA and MCRSA
  • What we can learn from the withdrawn MCRSA draft rules
  • General expectations for license applicants as rule-making continues

They will also take audience questions.

Please register for this free webinar here. We look forward to your attendance!