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The After-Tax Brief

A short weekly note on what changed in tax law, markets, and planning, and what it may mean for concentrated positions, liquidity events, and the accountants who work alongside them. Written to be read in five minutes.

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Oct 6, 2026
Tax law
6 min read

The IRS drew a line around Section 351 ETF exchanges. Here is what it covers and what it does not.

A new revenue ruling treats certain ETF seeding arrangements as taxable, and a companion notice flags several other tax-aware fund strategies. What it means if you hold a concentrated position, and the questions worth asking before you act on headlines.

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