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.
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.
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.
