Tax Alpha Insider comments for Treasury on Section 351 transfers

Tax Alpha Insider comments for Treasury on Section 351 transfers

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Seattle-area advisers... I'm considering a small event called Basis Pints (get it?) on Nov 18, 3-6 PM PT focused on year-end tax planning in Washington State.

I'm also organizing a "lightning round" where we have folks grab the mic for 5-10 min (maximum 1 slide) and present whatever on whatever is most relevant. These are a hoot.

Interested in joining or speaking? Please fill out this form.

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I started covering Section 351 ETF seeding in late 2024.

In early 2026, Elie Rozner and I published our article about Section 351 in The Journal of Wealth Management.

I track launches and the pipeline of Section 351 launches at 351.tax.

The latest node in this saga is certainly Treasury's September 28, 2026 release of Notice 2026-62 and Rev. Rul. 2026-20.

I covered the release with two tax attorney pals on an episode of The Albatross, which interestingly is my most popular episode as of this writing.

Treasury's Notice requested comments and mine are below in image and pdf.

Have a great weekend.

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