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Two reasons seeding ETFs in-kind is going mainstream

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Brent Sullivan
Mar 29, 2026
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351.tax is a little spicier now (hot pink is back, right?), and includes many more ETFs than I originally thought. Many were launched in March 2026.

Check out 351.tax

It’s funny. When I wrote Will seeding ETFs in-kind go mainstream? in December of 2024, things were just heating up.

Now, seeding ETFs in-kind seems like a mainstream inevitability.

There’s growth in launch assets (the chart above), and there are two other interesting indicators…

But first, some friendly visuals to get everyone up to speed.

A diversified portfolio (there’s a technical definition) may seed an ETF at launch via Section 351 of the Internal Revenue Code.

This isn’t an exchange fund.

If the seed portfolio is not diversified at the individual level, then those individuals are denied Section 351(a) nonrecognition. That means the transfer is taxed like a sale.

That’s the background… why do I think seeding ETFs is going mainstream?

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