I am negotiating an LOI and one of the <20% owners may roll equity and stay under the 20% threshold to avoid a PG on the SBA 7a debt. To make the equity roll more tax efficient, the sellers proposed executing a 368(a)(1)(F) reorganization to an LLC pre-close. They are taxed as an S-corp today.

What, if any, impact may this reorg have on me as the buyer?