Asset management partner Jeremy Smith and tax partners Pamela Glazier and Franziska Hertel participated in the June 8 panel discussion, “In-Kind ETF Seeding: An Introduction to 351 Transactions” at the ICI ETF Conference. They discussed key tax and 1940 Act considerations and constraints when seeding ETFs in kind at scale and on a tax-free basis.
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Asset management partner Jeremy Smith and tax partners Pamela Glazier and Franziska Hertel participated in the June 8 panel discussion, “In-Kind ETF Seeding: An Introduction to 351 Transactions” at the ICI ETF Conference. They discussed key tax and 1940 Act considerations and constraints when seeding ETFs in kind at scale and on a tax-free basis.
Firms face increased scrutiny as updated IRS guidance introduces new compliance considerations for ETF conversions under Section 351.
The Internal Revenue Service issued Notice 2026-14 clarifying holding period and continuity-of-interest standards that apply when mutual fund portfolios are contributed to newly organized ETF sponsors under Section 351.
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Asset management partner Jeremy Smith and tax partners Pamela Glazier and Franziska Hertel participated in the June 8 panel discussion, “In-Kind ETF Seeding: An Introduction to 351 Transactions” at the ICI ETF Conference. They discussed key tax and 1940 Act considerations and constraints when seeding ETFs in kind at scale and on a tax-free basis.
Firms face increased scrutiny as updated IRS guidance introduces new compliance considerations for ETF conversions under Section 351.
The Internal Revenue Service issued Notice 2026-14 clarifying holding period and continuity-of-interest standards that apply when mutual fund portfolios are contributed to newly organized ETF sponsors under Section 351.