Section 351 Exchange

Treasury Scrutiny of Tax-Aware ETF Strategies and What It Means for Section 351 Exchanges

Treasury and IRS Put Certain “Tax-Aware” Financial Product Strategies on Notice

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

Where Treasury Drew the Line on Tax-Aware ETFs

treasury-tax-aware-etfs-cover

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