Red flag: hey brent, we have a cool tax strategy, let's see how we can partner! Me: Send me a research paper, I'll gladly read it! Them: would rather tell you in a call. This kind of cleverness doesn't fly with me anymore. There's very very very little IP in tax strategy. The tax part should be insanely transparent. The IP should be the investment strategy, not the tax mechanics. So, these people pitching me are pitching the wrong thing and outing themselves as ding dongs along the way. Show me the hard thinking you did in written form so I can scrutinize it. I will study your work. Yes, packaging research content is a huge effort, but that's how you stand out. This may seem counterintuitive: with AI, anybody can write research! But thoughtful research reveals something interesting (curation) and proves you've at least considered tradeoffs (risk management) and 1,000x better contains proprietary data (complete moat against AI) or at least a replicable model. This combined package shows me you did the work that warrants attention, not even investment, just attention! But stop with the cloak and dagger tax pitch. That's dumb.

IRS on "solid ground" going after suspicious §351 transactions. Latest episode of The Albatross podcast goes deeper on Treasury's recent Notice and Ruling on IRC Section 351 used to seed exchange-traded funds in-kind. I speak with two tax attorneys who have structured more than 100 transfers, and we consider the difference between routine and aggressive planning. Special thanks to Robert Elwood and Raymond Holst for the conversation. The Albatross is educational content only. Hire tax counsel for personalized guidance. Get it wherever you get podcasts.

TL;DR on Treasury's Notice 2026-62 and Rev. Rul. 2026-20 yday regarding §351 and ETFs... Abusive §351 is dead Long live routine §351 Anyone arguing the extremes (§351 is entirely dead, or that Treasury will take no action), either... 1) hasn't read the Notice and Ruling, or 2) doesn't know how to read them I'll have a podcast out about this tomorrow. Get "The Albatross" wherever you get podcasts.