Matthew Bucklin of ExchangiFi - 351 Exchanges and New IRS Guidance

Ben Vaske talks with Matthew Bucklin, founder of ExchangiFi, about 351 exchanges — the process of moving concentrated stock positions into ETFs — and the role his firm plays as a marketplace connecting wealth advisors and asset managers. The conversation covers how a 351 exchange works, the 25/50 test and why Treasury and the IRS impose it, who the structure suits and who it does not, and the due diligence Bucklin says an ETF and its construction rules warrant. It closes on recent IRS guidance that put 351 exchanges in the news, Bucklin's reaction to it, his views on how these exchanges are marketed, and what advisors should check before or after completing one.

1. Bucklin describes ExchangiFi as a marketplace with wealth advisors on one side and asset managers on the other, and explains why a marketplace is needed for this kind of exchange.
2. He walks through a bird's-eye view of a 351 exchange in the ETF context and explains the 25/50 test from the Treasury and IRS perspective.
3. The episode covers reasons not to do a 351, which clients may not be a good fit, and the due diligence Bucklin considers necessary on the ETF itself and its construction rules.
4. Discussion includes custodian reporting, cost-basis transfer and timing windows, where those have gone wrong, and the recent rulings that put 351 exchanges in the news, plus whether he plans to submit comments by the late October deadline.