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Ray Holst

Partner and U.S. federal income tax attorney at Practus, LLP, known for Section 351 transactions and in-kind ETF seeding.

Oct 5, 2026

18:08
And I would say certainly after 30 or 90 days, that's a fairly meaningful exposure to the economics of the particular investment.
18:16
I was just going to take the question of materiality.
18:19
And here's how I look at that.
18:21
In the revenue ruling, they wrote it in such a way that there's only one transfer or.
18:25
So the transfer or contributes to the portfolio, and that portfolio is materially different after the rebalance using 852B6.
18:34
But if you take a case where, let's say, we have three transfer ors, and we're trying to construct the S&P 500 largest stocks, and each of us contribute 166 stocks, And that portfolio now represents in the same proportions as the S&P 500.
18:51
And the investment manager is OK with that.

11 MINS LATER

29:38
and the tax benefit side to side.

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