Section 351 Exchange

Where Treasury Drew the Line on Tax-Aware ETFs

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Key takeaways from the Wall Street Tax Association panel with Treasury and IRS officials, July 2026. Treasury and the IRS spent Tuesday morning walking through the tax-aware product strategies they are watching. It was a Wall Street Tax Association seminar with Kevin Salinger and Erika Nijenhuis from Treasury’s Office of Tax Policy, alongside partners from … Read more

The Guardrails That Decide Who Gets to Access the $5.0 Trillion Market

Guardrails That Decide Who Gets to Access the $5.0 Trillion Market

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