Brent Sullivan(@TaxAlphaInsider):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.

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.

参加 August 2023

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Brent Sullivan@TaxAlphaInsider

2026.10.06 11:52

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.