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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.
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Oct 5, 2026
IRS on "solid ground" going after suspicious §351 transactions - Bob Elwood and Ray Holst
18:08

Bob ElwoodGUEST
And I would say certainly after 30 or 90 days, that's a fairly meaningful exposure to the economics of the particular investment.
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18:21Ray HolstGUEST
In the revenue ruling, they wrote it in such a way that there's only one transfer or.
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18:25Ray HolstGUEST
So the transfer or contributes to the portfolio, and that portfolio is materially different after the rebalance using 852B6.
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18:34Ray HolstGUEST
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.
11 MINS LATER