IRS names "subject transactions" and rules against abusive §351 ETF conversions [annotated]

IRS names "subject transactions" and rules against abusive §351 ETF conversions [annotated]

The latest episode of The Albatross is about Exchange Fund Replication, a 4-legged options strategy to hedge and replace single-stock risk with index risk.

 
 
 
 
 
 
 
 
 
 
 
 
 
The Albatross podcast
Concentrated wealth risk & tax
Listen on Spotify →

The tax-aware adviser community is coming soon.

The community is for Tax Alpha Insider paid members that advise households: planners, advisers, CPAs, attorneys, family office professionals, etc.


Yesterday, Treasury followed up the July Wall Street Tax Association seminar with a Notice about several "subject transactions" and a Revenue Ruling targeting abusive §351 transactions.

TL;DR: Treasury wants more information on two groups of "subject

4x per week · Full archive · Cancel anytime

Quoted in WSJ, Bloomberg, and Barron’s. Published in The Journal of Wealth Management.