VPF + tax-aware long/short for diversifying concentrated stock
Plenty more content coming on this strategy...
What I’m reading…
AQR: Strategies to Diversify Low-Basis Stock
AQR: A Brief Guide to Pricing and Taxation of Variable Prepaid Forwards
AQR: Combining VPFs and Tax-Aware Strategies to Diversify Low-Basis Stock
Bob Gordon (2001): Wall Street Secrets for Tax-Efficient Investing
Tax Foundation: “Big, Beautiful Bill” Senate GOP Tax Plan
Eide Bailly: Washington State Increases Estate and Capital Gains Taxes
Perkins Coie (2023): Washington Capital Gains Tax: More Questions, Tentative Answers
VPF + Tax-Aware Long/Short for diversifying concentrated stock
Tax-aware long/short + variable prepaid forward is 🤯 for diversifying low-basis stock. Here's how it works:
t = 0
• Pledge shares; set delivery collar (e.g. 15 pt window)
• Receive ≳ 90% cash loan; no tax event
• Invest in tax-aware long/short
0 < t < T (maturity e.g. 2 years)
• Hold shares; receive dividends (taxed on receipt)
• Handle margin calls if price drops below haircut
• Loan accrues interest at negotiated financing rate
• Tax-aware long/short generates alpha/capital losses
t = T
• Deliver shares (cash top-up) within collar limits
• Pay accrued interest
• Realize deferred gain = prepayment – tax basis
• Tax-aware long/short offsets deferred gain (and some)
AQR research conclusion (see image)...
"𝘸𝘦 𝘥𝘰 𝘯𝘰𝘵 𝘧𝘪𝘯𝘥 𝘤𝘰𝘯𝘤𝘭𝘶𝘴𝘪𝘷𝘦 𝘦𝘷𝘪𝘥𝘦𝘯𝘤𝘦 𝘵𝘩𝘢𝘵 𝘢 𝘝𝘗𝘍 𝘤𝘰𝘮𝘣𝘪𝘯𝘦𝘥 𝘸𝘪𝘵𝘩 𝘢𝘯 𝘪𝘯𝘥𝘦𝘹 𝘧𝘶𝘯𝘥 𝘰𝘳 𝘢 𝘥𝘪𝘳𝘦𝘤𝘵-𝘪𝘯𝘥𝘦𝘹𝘪𝘯𝘨 𝘴𝘵𝘳𝘢𝘵𝘦𝘨𝘺 𝘰𝘶𝘵𝘱𝘦𝘳𝘧𝘰𝘳𝘮𝘴 𝘢𝘯 𝘶𝘱𝘧𝘳𝘰𝘯𝘵 𝘴𝘢𝘭𝘦 𝘰𝘧 𝘵𝘩𝘦 𝘴𝘵𝘰𝘤𝘬 𝘢𝘯𝘥 𝘪𝘯𝘷𝘦𝘴𝘵𝘮𝘦𝘯𝘵 𝘰𝘧 𝘵𝘩𝘦 𝘴𝘢𝘭𝘦 𝘱𝘳𝘰𝘤𝘦𝘦𝘥𝘴 𝘪𝘯 𝘢𝘯 𝘪𝘯𝘥𝘦𝘹 𝘧𝘶𝘯𝘥. 𝘐𝘯 𝘤𝘰𝘯𝘵𝘳𝘢𝘴𝘵, 𝘢 𝘝𝘗𝘍 𝘤𝘰𝘮𝘣𝘪𝘯𝘦𝘥 𝘸𝘪𝘵𝘩 𝘭𝘰𝘯𝘨-𝘴𝘩𝘰𝘳𝘵 𝘴𝘵𝘳𝘢𝘵𝘦𝘨𝘪𝘦𝘴 𝘳𝘦𝘴𝘶𝘭𝘵𝘴 𝘪𝘯 𝘢 𝘴𝘪𝘨𝘯𝘪𝘧𝘪𝘤𝘢𝘯𝘵 𝘰𝘶𝘵𝘱𝘦𝘳𝘧𝘰𝘳𝘮𝘢𝘯𝘤𝘦 𝘰𝘧 𝘵𝘩𝘦 𝘶𝘱𝘧𝘳𝘰𝘯𝘵 𝘴𝘢𝘭𝘦 𝘢𝘯𝘥 𝘳𝘦𝘪𝘯𝘷𝘦𝘴𝘵𝘮𝘦𝘯𝘵 𝘰𝘧 𝘱𝘳𝘰𝘤𝘦𝘦𝘥𝘴 𝘪𝘯 𝘢𝘯 𝘪𝘯𝘥𝘦𝘹 𝘧𝘶𝘯𝘥."
AQR: Liberman, J., & Sosner, N. (Spring 2025). Combining Variable Prepaid Forwards and Tax-Aware Strategies to Diversify Low-Basis Stock. The Journal of Wealth Management, 27(4).
I’m building a tax-aware long/short visualizer
Most folks haven’t heard of tax-aware long/short. Those who have could probably use a hand ramping on the details and explaining to clients.
This should help people understand, for instance, the impact on cost basis following loss harvest and why long/short doesn't easily lock up like long only.
Shown: 150/50 using correlated geometric brownian motion, 500 long positions, 250 positions in each extension, equal.
¡¡¡Definitely not backtest or simulation quality!!!
Purely for explaining portfolio and tax mechanics. It’s an educational tool.
Washington State capital gains increases
Planning opportunity for WA-focused advisers…
Notes (See Perkins Coie 2023)
WA taxes federal net LTCG only; short-term gains/losses ignored
Grantor CRUTs pass through LTCG to you (taxable even if undistributed)
Nongrantor CRUTs unclear—no DOR guidance; audit risk on trust vs. grantor status
CRUT payouts don’t qualify for WA’s charitable-deduction offset
Only individuals pay WA CGT; true non-grantor trusts/estates may avoid it
Additional quirks:
§1256 contracts: WA may tax the 60% “long-term” portion even if held <1 yr
QSBS gap: No carve-out for §1202-excluded gains: likely taxed
Loss carryforwards: Only federal LT loss carryforwards apply; no WA-only system
Small-biz deduction: Family-owned business gains fully deductible per entity, no cap
DAF gifts: Donor-advised fund donations don’t qualify for the $100K offset
Pre-2022 sales: Installment gains before Jan 1 2022 exempt; related loss carrybacks added back
This VPF + tax-aware long/short paper is quite interesting, but I'd argue that the assumptions embedded in exhibit 1 (the chart from the paper which is included here) are too rosy. They assume positive alpha (net of fees & costs) for the long/short strategy. So it is no surprise that leads to results which look quite good.
For looking specifically at the usefulness of the tax strategy being discussed here, exhibit 6 is a much better data point as it assumes zero alpha net of costs & fees. I wish they'd continued that line of analysis further as the numbers I'd like to see is for each of the listed strategies, what amount of fees & costs would offset the benefit vs. the sell-upfront strategy. That would be valuable to assess how that amount compares with typical costs for a 150/50 tax-aware long/short strategy.
Contact me regarding IRC 351 and LCOR that's launching next month. mark@frplan.com