Brent Sullivan(@TaxAlphaInsider):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.

Brent Sullivan

@TaxAlphaInsider

Tax analyst. ETFs, direct indexing, long/short, bonds, options, partnerships, you name it. I'm going to ask you about economic substance.

Joined August 2023

773 Following 4.1K Followers

Brent Sullivan@TaxAlphaInsider

2026.09.29 16:42

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.