On Aug 6, 2026, the Tax Court released an opinion on SIH Partners v. Commissioner regarding a trade from 2010 to 2013, ultimately denying tax benefits for 2012.
I published an annotated version of the opinion earlier this week if you want the highlights.
Since the opinion concerned long and short positions, most people immediately started thinking about its relevance to long/short strategies.
Get up to speed on long/short strategies.
But long/short as we know it today is vastly different from what the SIH Partners Tax Court opinion addresses (for example, long/short strategies use non-identical, physical positions), and this will take me a while to unpack.
However, I noticed some applications in the world of ETF seeding (Section 351), which Elie and I wrote about in The Journal of Wealth Management.