Treasury and the IRS have put certain tax-aware financial product strategies on notice. A recent Perkins Coie panel moderated by Mohsen Ghazi, with partners Sharon Kim and Vivek Chandrasekhar, walked through what that scrutiny actually covers. The short version is that ordinary ETF activity and ordinary tax loss harvesting are not the target. Stacked structures … Read more
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
Our site uses cookies to enhance your experience. Many are necessary to make our site function. Additional cookies help us understand site usage, make site improvements, provide enhanced functionality and personalisation, serve personalised ads or content based upon web browsing activity.
By clicking “Accept all cookies” you consent to our use of cookies as described in our cookies and online tracking disclosure. Click on “Cookie settings” to manage your cookie preferences. This link can be found at the bottom of every page.
This website provides general information only and is not financial, investment, legal, or tax advice.
Manage your cookie preferences below:
Essential cookies enable basic functions and are necessary for the proper function of the website.
CloudFlare provides web performance and security solutions, enhancing site speed and protecting against threats.
Service URL: developers.cloudflare.com (opens in a new window)
Google Tag Manager simplifies the management of marketing tags on your website without code changes.
WP Consent API is a plugin that standardizes the communication of accepted consent categories between plugins.
Statistics cookies collect information anonymously. This information helps us understand how visitors use our website.
Google Analytics is a powerful tool that tracks and analyzes website traffic for informed marketing decisions.
Service URL: policies.google.com (opens in a new window)
HubSpot is an all-in-one marketing, sales, and customer service platform that streamlines business growth.
Service URL: legal.hubspot.com (opens in a new window)
Jetpack's built-in visitor analytics. It records page views, referring sites, search terms, and outbound link clicks, and also carries the shared visitor-tracking library used by Jetpack Instant Search and WooCommerce Analytics.
Service URL: automattic.com (opens in a new window)
Klaviyo is a marketing automation platform designed for e-commerce businesses to enhance customer engagement and drive sales.
Marketing cookies are used to follow visitors to websites. The intention is to show ads that are relevant and engaging to the individual user.
Service URL: advizorpro.com (opens in a new window)
Facebook Pixel is a web analytics service that tracks and reports website traffic.
Service URL: www.facebook.com (opens in a new window)
HubSpot is an all-in-one marketing, sales, and customer service platform that streamlines business growth.
Service URL: legal.hubspot.com (opens in a new window)
LinkedIn Insight is a web analytics service that tracks and reports website traffic.
Service URL: www.linkedin.com (opens in a new window)
Service URL: www.rb2b.com (opens in a new window)
X Pixel enables businesses to track user interactions and optimize ad performance on the X platform effectively.
Service URL: x.com (opens in a new window)
You can find more information in our Cookie Policy and Privacy Policy.
