A syndicated 351 exchange is a sophisticated tax strategy that allows multiple investors to pool their diversified, appreciated portfolios into a newly created ETF without triggering immediate capital gains taxes. Under Section 351 of the Internal Revenue Code, investors contribute their securities to the ETF in exchange for shares, provided the transferred portfolios meet diversification requirements (the 25/50 rule) and the transferors collectively control at least 80% of the new ETF. This process preserves the original cost basis and holding period of the contributed assets while providing investors with the operational benefits of ETF ownership, including enhanced liquidity, simplified portfolio management, tax-efficient in-kind rebalancing through heartbeat trades, and access to a broader investor base.