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351 Conversions: Smart Tax Alpha Strategy or Loophole in the Code?

August 13, 2026 · 31 min

Show notes

ETFs are already famous for their tax efficiency, but a growing corner of the market is pushing those benefits further than ever. What if you could sell a massive stock position without paying taxes on it - at least not yet?  Welcome the 351 conversions - custom built funds that allow investors to swap concentrated stock positions into diversified portfolios without paying gains taxes. 

On this episode of Trillions, Joel Weber and Eric Balchunas dig into the growing world of 351 conversion ETFs and how it actually works. Bloomberg News reporters Denitsa Tsekova and Zachary Mider, two of the journalists behind the story "The Latest Tax Dodge For the Ultra-Rich Is a Customized ETF,” join the conversation. Is this a smart tax alpha strategy or a cheat code in the tax  system? Where will the IRS draw the line? They break down how the 351 conversion actually works, why the Treasury officials are taking closer look and how billionaires like the family behind the Hot Pockets are using them.

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