Mayer Brown·TAX
IRS Flags 351 Exchanges Into ETFs and Other Fund Strategies as Abusive
A Mayer Brown alert reports the IRS is scrutinising "351 conversion" transactions and other ETF and investment-fund structures as potentially abusive, a signal tax counsel should watch for follow-on guidance.
irssection-351etfinvestment-fundstax-avoidanceabusive-tax-strategies
Read the original firm alert → Saturday, October 3, 2026