Tracking the Latest Shifts in Section 351 Exchanges: Guidance, Policy, and Market Impact
The landscape of Section 351 exchanges continues to evolve as regulators, lawmakers, and market participants respond to the growing use of tax-deferred contribution structures—particularly in the context of ETF conversions. Recent updates from the Internal Revenue Service have placed renewed focus on how continuity-of-interest requirements are applied, signaling a more structured approach to transactions that were previously considered routine.