Section351Exchange.com
Effective Date: May 30, 2025
General Disclaimer
Section351Exchange.com is owned and operated by ExchangiFi, LLC, a Delaware limited liability company (“ExchangiFi”). The information on this Site is provided for general informational and educational purposes only. It is intended for use by financial professionals and is not suitable for retail investors or members of the general public.
Nothing on this Site should be construed as investment advice, legal advice, tax advice, financial planning advice, or a recommendation of any kind. ExchangiFi is not a registered investment adviser, broker-dealer, statutory underwriter, transfer agent, or law firm. ExchangiFi does not provide personalized advice of any kind to any person or entity.
No Offer or Solicitation
Nothing on this Site constitutes an offer to sell or a solicitation of an offer to buy any security, investment product, exchange-traded fund, or other financial instrument. Any such offer or solicitation will be made only by and through appropriate offering documents, in compliance with applicable federal and state securities laws, and only to persons to whom such an offer may lawfully be made.
Investment Risk Disclosure
All investments involve risk. The value of any investment may go up or down, and investors may receive back less than they originally invested. Past performance is not indicative of future results. There is no guarantee that any investment strategy, including a Section 351 exchange transaction, will achieve its objectives.
Exchange-traded funds (ETFs) are subject to market risk, including the possible loss of principal. ETF shares are bought and sold at market price, which may differ from the fund’s net asset value (NAV). ETFs may trade at a premium or discount to NAV. Brokerage commissions and other transaction costs will reduce investment returns.
Diversification does not guarantee a profit or protect against loss in declining markets.
No Tax Advice — Section 351 Specific Disclosure
ExchangiFi does not provide tax advice. Nothing on this Site constitutes tax advice or a legal opinion regarding the tax treatment of any transaction. The information provided about Section 351 of the Internal Revenue Code is general and educational in nature only.
Section 351 tax-deferred exchange transactions are complex and fact-specific. The availability and scope of tax-deferred treatment under Section 351 depends on numerous factors, including but not limited to:
- The specific securities contributed and received
- The structure and timing of the transaction
- The composition of the ETF and control requirements under Section 351(a)
- Whether the transaction satisfies the requirements of Sections 351, 357, 358, and 362 of the Internal Revenue Code
- The contributor’s specific tax situation, holding period, cost basis, and applicable state and local tax obligations
- Applicable Treasury Regulations and IRS guidance, which may change
Tax-deferred treatment is not guaranteed in any Section 351 exchange transaction. The IRS may challenge the tax treatment of a Section 351 exchange, and there is no assurance that any position taken will be sustained upon examination. Changes in tax law, regulations, or IRS guidance could adversely affect the tax consequences of a Section 351 exchange, potentially with retroactive effect.
You should not enter into any Section 351 exchange transaction without first consulting a qualified independent tax advisor and legal counsel who can evaluate your specific circumstances. Do not rely on any information found on this Site as a basis for making tax or legal decisions.
No Legal Advice
Nothing on this Site constitutes legal advice or creates an attorney-client relationship. Regulatory requirements applicable to Section 351 exchange transactions, ETFs, investment advisers, and broker-dealers are complex and subject to change. You should consult qualified legal counsel before taking any action based on information found on this Site.
Forward-Looking Statements
This Site may contain statements about potential benefits, outcomes, or features of Section 351 exchange transactions or ExchangiFi’s platform. These statements are not guarantees. Actual results may differ materially from any outcomes discussed or implied. ExchangiFi undertakes no obligation to update any forward-looking statements.
Third-Party Information
This Site may reference third-party data, research, publications, or websites. ExchangiFi does not endorse or take responsibility for the accuracy or completeness of any third-party information. Such references are provided for convenience only.
Regulatory Status
ExchangiFi, LLC is not registered with the U.S. Securities and Exchange Commission (SEC) or any state securities regulator as an investment adviser or broker-dealer. ExchangiFi operates an informational marketplace platform and does not execute securities transactions, provide investment recommendations, or manage client assets.
State Law Considerations
Securities laws vary by state. Information on this Site does not account for the laws and regulations of any particular jurisdiction. Nothing on this Site should be construed as an offer or solicitation in any jurisdiction where such an offer or solicitation would be unlawful.
Contact Us
If you have any questions about these disclosures, please contact us at:
ExchangiFi, LLC Attn: Legal Palm Beach Gardens, Florida Section351Exchange.com