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