Tax Alpha Insider

Tax Alpha Insider

Why seed an ETF in-kind only to sell a few months later?

Selling should undo the tax benefits of seeding in-kind... right?

Brent Sullivan's avatar
Brent Sullivan
Jul 27, 2025
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Twin Oak Active Opportunities ETF (TSPX) launched in February 2025 with around $440,000,000 in assets.

Justina Lee wrote about it for Bloomberg last week. So did Matt Levine.

TSPX was seeded in-kind with DDOG, SNOW, and 3 ultra-short income ETFs.

IRC Section 351 allows investors to seed ETFs in-kind (provided they meet diversification and other requiremen…

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