We are selling one of our operating units back to the former private owner. The private owner is implementing benefit plans for the employees as of the sale date.
Do we need to offer COBRA?

Normally, the seller is responsible for COBRA obligations to qualified beneficiaries whose qualifying events occurred prior to the sale. If the buyer is picking up all the eligible employees, any future COBRA beneficiaries are their responsibility. If for some reason one or more employees are not hired (or provided insurance), the seller is responsible for offering COBRA.