Perkins Coie·TAX

IRS Backs Tax Treatment of Some Section 351 ETF Conversions, Treasury Widens Review

Treasury and the IRS have taken a further step against tax-aware fund structures, treating certain Section 351 ETF conversions as taxable — a signal that scrutiny of exchange-fund and similar tactics is broadening.

irstreasuryetf-conversionsection-351tax-aware-investingfund-structuring
Read the original firm alert → Saturday, October 3, 2026

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