Section 351 ETF

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Most American equity wealth sits in a few hands, has risen far above what it cost, and cannot be moved without a large capital gains tax bill. Section 351 of the tax code allows for a tax-deferred reorganization of that equity into exchange-traded funds. This paper measures the opportunity, explains how it works, and argues that, set against what these investors already do, it costs the Treasury little or nothing.

Most American equity wealth sits in a few hands, has risen far above what it cost, and cannot be moved without a large capital gains tax bill. Section 351 of the tax code allows for a tax-deferred reorganization of that equity into exchange-traded funds. This paper measures the opportunity, explains how it works, and argues that, set against what these investors already do, it costs the Treasury little or nothing.

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Most American equity wealth sits in a few hands, has risen far above what it cost, and cannot be moved without a large capital gains tax bill. Section 351 of the tax code allows for a tax-deferred reorganization of that equity into exchange-traded funds. This paper measures the opportunity, explains how it works, and argues that, set against what these investors already do, it costs the Treasury little or nothing.