Why $5.0 Trillion in Embedded Gains Makes 351 Conversions a Macro Trend
The scale of unrealized capital gains in American portfolios is not a side effect of the tax code. It is the dominant fact of taxable wealth management. New research from ExchangiFi quantifies it. Of the $57.7 trillion households hold in equities and fund shares, an estimated $5.0 trillion sits in structures where the realization cost […]
Why Wirehouses Won’t Do a 351 Exchange for HNW Clients
You hold a concentrated stock position. The gains are large. The risk is real. You ask your advisor at Morgan Stanley, Merrill Lynch, UBS, Goldman Sachs, JP Morgan, or Wells Fargo about a Section 351 exchange. The answer comes back as some version of no. The transaction is not improper. Section 351 is codified in […]