Name
Financial Products: Section 852(b)(6) Under the Microscope: ETF Planning in Focus
Date & Time
Thursday, January 14, 2027, 10:30 AM - 11:45 AM
Description

ETFs' routine reliance on Section 852(b)(6) for tax-free in-kind redemptions is well accepted, but certain applications — including Section 351 seeding transactions, tiered ETF-of-ETF structures, box-spread and other option strategies, crypto currency distributions, and loss-generation techniques — have recently drawn heightened attention and calls for industry input on whether further guidance is warranted. This panel examines the transactions raising questions, the line between ordinary-course use and more aggressive planning, and what issuers and advisers should anticipate as scrutiny of these structures grows.