What if trader fund ordinary losses were considered passive?
The 1940s tax shenanigans offering some insight into §351 ETF seeding today
Concentrated wealth: investor goals first, solutions second
Too much tax alpha, too little diligence with Steve Curley
Abusive §351 is dead, long live routine §351
![IRS names "subject transactions" and rules against abusive §351 ETF conversions [annotated]](https://storage.ghost.io/c/62/a7/62a7f847-3269-4825-b59c-a39b8b2d4251/content/images/size/w800/format/webp/2026/09/tl-dr.png)
IRS names "subject transactions" and rules against abusive §351 ETF conversions [annotated]
![IRS names "subject transactions" and rules against abusive §351 ETF conversions [annotated]](https://storage.ghost.io/c/62/a7/62a7f847-3269-4825-b59c-a39b8b2d4251/content/images/size/w800/format/webp/2026/09/Screenshot-2026-09-28-at-9.57.27---PM.png)
IRS names "subject transactions" and rules against abusive §351 ETF conversions [annotated]
Interactive Brokers on the Record: Why Tax-Aware Advisors are Taking a Closer Look at IBKR
Replicating an exchange fund using options and a brokerage account
Long/short: top 5 categories of questions ~340 advisers asked on a webinar yesterday
Tax-aware long/short biggest differentiator is ironically pre-tax alpha
The hip new thing in tax diligence is "regime resilience"
Covered Calls Are Not For Hedging
WING, DING, NING... for concentrated stock privacy and planning
Tax on the beach... see you at Future Proof
The Cost of Holding a Concentrated Position with Antti Petajisto
Spider graphs for comparing concentrated stock exit strategies
Long/short... what's a series LLC?
Basis Manhattan is Dec 3-4, 2026
Schwab's new long/short limits "kneecap" concentrated wealth solution
The Albatross: Opportunity Zones Won't Save a Bad Deal, But Can Accelerate a Good One
Schwab is increasing long/short account minimums and limiting portfolio margin
Investors have seeded 113 ETFs with appreciated assets
Why you can't use munis as long/short collateral
Paul Bouchey on The Albatross podcast
The cost of holding a concentrated position
Back to boring: the tax alpha vibe shift
Covered calls for managing concentrated stock?
Taxable wealth community launching soon
The right wrapper for a Qualified Opportunity Fund
Opportunity Zones: States chipping away at federal tax perks
Long/short: skip Fidelity/Schwab with an LLC or LP
Introducing: The Albatross Podcast
What SIH Partners means for seeding ETFs in-kind (§351)
SIH Partners annotated Tax Court opinion
0% tax is an act of Congress
Two Papers in The Journal of Wealth Management
The long/short steam engine
An infographic tax history of ETFs and exchange funds
Long/short: 3 ways advisers are getting around Fidelity/Schwab strictures
