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Directors Removing Directors

Seven years ago, I addressed the question of whether the board of directors of a California corporation could remove a fellow director...more

Does Guzman Supply An Answer To Moelis?

I always enjoy hearing from readers of this blog.  Recently, I wrote: Reading these statutes together, it is relatively clear that Nevada, like Delaware, permits the articles of incorporation to vary the mandate that...more

No Exit: Stockholders Fail To Grant Leave To Leave Delaware For Nevada

In news that should cheer hearts in Delaware, the stockholders of Fidelity National Financial, Inc. last week failed to approve a proposal to convert the corporation from a Delaware to a Nevada corporation.  I characterize...more

Don't Be Caught Inquorate! Some Key, But Subtle, Differences In California's And Nevada's Board Quorum Requirements

California Corporations Code Section 307(a)(7) provides that a "majority of the authorized number of directors constitutes a quorum for the transaction of business".  Thus, if the authorized number of directors is 7 and there...more

Nevada Supreme Court Follows Delaware In Overruling Gentile v. Rosette

The line between a direct and derivative action is often indistinct and hence the object of controversy. In 2017, the Nevada Supreme Court held that a class action lawsuit should be dismissed for failure to plead a...more

Selling Unqualified Securities?  There's Are/Were Apps For That

If someone told my younger self that someday people would take photographs with their phones, I would have wondered where you would insert the film.*  Today, the question would be "What is film?"  When I headed the Department...more

Beneficial Ownership Reporting May Soon Be Coming To California With A Brobdingnagian Price Tag!

Beginning January 1, 2024, many companies became subject to the beneficial ownership reporting requirements of the Corporate Transparency Act.   The Financial Crimes Enforcement Network (FinCEN) estimated that the total costs...more

Home Means Nevada For This Corporation, But Its Heart Remains Exclusively With The Delaware Court Of Chancery

In 2019, the Nevada legislature added a provision to the state's corporate law permitting the articles of incorporation or bylaws to require, to the extent not inconsistent with any applicable jurisdictional requirements and...more

Converting A Corporation Is Not Domestication

In a recent post, I took note of another Delaware corporation that had disclosed plans to convert to a Nevada corporation.  The Form 8-K filed by this company included the following statement...more

Is There A California Connection To Kirschner?

Last summer, bankers and the lawyers who advise them breathed a collective sigh of relief when the Second Circuit Court of Appeals  upheld a U.S. District Court's opinion that notes in a bank syndicated loan were not...more

Judge Finds Demand Futility Is A "Live" Issue

A recent ruling by U.S. District Court Judge Anthony J. Battaglia addresses whether demand futility is an affirmative defense that must be asserted in an answer or raised in a motion to dismiss.  In re Franklin Wireless, 2024...more

Not Every California Corporation Is Governed By The California General Corporation Law

The California General Corporation Law is part of the California Corporations Code, but not every corporation incorporated in California is formed or governed by the General Corporation Law.   In fact, the Corporations Code...more

What Egregious Error Have Courts Made Nearly 9,000 Times (And Counting)?

In a recently published article, Professors Samantha J. Prince & Joshua P. Fershée focus on the propensity to conflate corporations with limited liability companies...more

Do E-mail Exchanges Constitute A Meeting Of The Board?

I recently discussed whether chat messages constitute "minutes" of a meeting.  A related question is whether emails constitute a meeting....more

Judge Rules That A Front For Mexican Cartel Had The Capacity To Protect Its Own Interests

California Corporations Code Section 25118(b) provides an exemption from the state's usury limitations for loans.  The exemption is subject to several conditions.  One condition is the existence of either a preexisting...more

Reverse Stock Splits And The California Corporate Securities Law

Meredith Ervine recently wrote about reverse stock splits and Nasdaq listed issuers.  A reverse stock split is the "go to" solution for many listed issuers whose share prices fall below the minimum continued stock exchange...more

Judge Rules Plaintiff Lacked Standing To Claim Damages Whilst Still Holding Securities

Part 5 of the California Corporate Securities Law of 1968 sets forth a number of fraudulent and prohibited practices.  One of these practices is to "to offer or sell a security in this state, or to buy or offer to buy a...more

Can A Member Bring A Derivative Action On Behalf Of A California Nonprofit Corporation?

Like many questions in the law, the answer to the question of whether a member of a California nonprofit corporation may maintain a derivative action is "it depends"....more

California Legislator Proposes To Enhance Criminal Fines For California, But Not Delaware, Business Entities

In February of this year, California Assembly Member Jesse Gabriel introduced a bill making certain technical, nonsubstantive changes to a provision of the Penal Code concerning the removal of prison inmates for court...more

Does The State Make Or Beget Corporations?

To non-lawyers, a "person" is usually understood to refer to a human being.  At law, entities such as corporations and limited liability persons are often endowed with personhood.  See, e.g., Cal. Corp. Code § 18 ("'Person'...more

Can Any Superior Court Judge Access Your Church's Books?

The California Corporations Code allows for the incorporation of a corporation sole by the bishop, chief priest, presiding elder, or other presiding officer of any religious denomination, society, or church, for the purpose...more

Bill Would Vest Secretary Of State With Broad Powers To Cancel Business Entities

Last month, California State Senator Monique Limón introduced a bill, SB 1168,  that would endow the California Secretary of State with the power to cancel the articles of a domestic corporation or the filing of a statement...more

What Exactly Must A Board Approve When It Approves A Merger?

Last Friday, John Jenkins wrote about another momentous ruling by Chancellor Kathaleen St. J. McCormick.  In Sjunde AP-Fonden v. Activision Blizzard, Inc., 2024 WL 863290 (Del. Ch. Feb. 29, 2024), she ruled...more

For How Long Is That Proxy Valid?

Section 705(a) of the California Corporations Code provides that no proxy is valid after the expiration of 11 months from the date thereof unless otherwise provided in the proxy.  This is a reflection of the fact that proxies...more

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