Matthew Bucklin 
ExchangiFi’s new white paper sizes the Section 351 conversion opportunity at an estimated $5.0 trillion. The number gets the attention. The compliance architecture decides who can actually use it. Section 351’s nonrecognition treatment is conditional, and the conditions are unforgiving. The central obstacle is Section 351(e). To stop investors from pooling concentrated stock into instant … Read more
Here is a comprehensive list of the legal authorities, statutes, regulations, rulings, cases, and doctrines that support and govern the legality of a Section 351 exchange of securities into an ETF: Internal Revenue Code (IRC) Statutes The foundation of the tax-deferred conversion relies on specific sections of the IRC governing corporate formations and investment companies: … Read more
Most failed Section 351 exchanges do not fail because the strategy is wrong. They fail because of preventable errors that surface late in the process or, worse, after the transaction has closed. The tax authority is well established. The mechanics are well understood. The errors are usually in the execution. This guide walks through the … Read more
