IRS on "solid ground" going after suspicious §351 transactions - Bob Elwood and Ray Holst

Last week, Treasury released Notice 2026-62 and Rev. Rul. 2026-20 concerning IRC §351 transactions, nowadays popularly used to seed new exchange-traded funds (ETFs) in-kind.Bob Elwood is the founder of Practus and he and his partners, including Ray Holst, have collectively structured more than 100 §351 transfers over the past several years. In this episode, Bob and Ray talk about the difference between routine and aggressive planning using §351, and the nuances of some of the key words in the new revenue ruling.Bob and Ray are tax attorneys, but they are not your tax attorneys. For specific and personalized guidance, hire tax counsel. This content is education only.