Trust Participation in Section 351 Tax-Free Exchanges: A Comprehensive Analysis
Section 351 of the Internal Revenue Code represents one of the most valuable tax planning tools available for corporate transactions, allowing for the tax-free transfer of property to a corporation in exchange for stock. However, when trusts are involved in these transactions, practitioners often encounter uncertainty regarding the eligibility and treatment of these entities as […]
Heartbeat Trades: The Tax-Efficient Secret Behind ETF Rebalancing
In the complex world of exchange-traded funds (ETFs), a sophisticated strategy known as “heartbeat trades” has been quietly revolutionizing how these investment vehicles manage their portfolios while maximizing tax efficiency. Named by analyst Elisabeth Kashner for their distinctive spike patterns that resemble an electrocardiogram, these transactions are becoming increasingly important in the ETF ecosystem—and they’re […]
How Smart Investors Use ETFs to Defer Taxes When Rebalancing Their Portfolios
If you’re managing a large investment portfolio, you’ve probably faced this dilemma: your investments have grown significantly, but they’re no longer balanced the way you want. The problem? Selling to rebalance could trigger massive tax bills that eat into your gains. Enter ETFs and a little-known tax strategy called “351 exchanges” – a perfectly legal […]