Rules & Regulation
Key SEC and IRS rules for a 351 conversion, including diversification tests, custodial setup, prospectus alignment, and eligibility factors.
Knowledge Hub
Tax savings analyses, cost basis strategies, exchange mechanics, and regulatory insights on Section 351 conversions. All in one place, built for advisors and investors who want the data behind the decision.
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A Tax Loophole for the Elite: How the Wealthy Can Avoid Capital Gains Indefinitely
Discover how Section 351 conversions and ETFs allow indefinite tax deferral and why this strategy is often seen as a loophole for wealthy investors.
The “Look-Through” Rule: A Closer Look at ETF Diversification in 351 Exchanges
Understand the look-through rule in 351 exchanges and how ETF diversification impacts IRS compliance and tax-deferred portfolio transfers.
Breaking Down Exchange Funds vs. Exchange-Traded Funds (ETFs): How Investors Can Diversify Without Tax Pain
Learn the differences between exchange funds and ETFs and how each helps investors diversify while minimizing or deferring capital gains taxes.
Got Crypto? Why Direct Contributions to New ETFs Are a Tough Sell
Direct crypto-to-ETF contributions via Section 351 are limited by regulations and ETF structures, with only narrow possibilities through existing crypto ETFs.
Understanding the Complexities of Section 351 Exchange
Section 351 exchanges enable tax-free asset transfers into ETFs, but require strict compliance with diversification and control rules.