How to exempt capital gains from tax

People who have massive capital gains (like @intercst or @OrmontUS ) have a way to exempt capital gains from tax. This one is new to me - I never heard of it before.

https://www.wsj.com/finance/investing/the-tax-strategy-for-people-suffering-from-stock-market-success-90b115e0?mod=hp_lead_pos8

The Tax Strategy for People Suffering From Stock-Market Success

If big gains on stocks have locked you in place, here’s one way to break free

By Jason Zweig, The Wall Street Journal, July 17, 2026


Exchange-traded funds offer a potential solution. In what’s called a 351 exchange, you can contribute shares of one or more stocks—or ETFs, for that matter—to the launch of an ETF. In return, you get shares of the newly minted ETF with the same total value.

You no longer own the original stock directly; it’s become part of the diversified basket of stocks held by the new ETF. You won’t owe capital-gains tax until you sell the ETF. You’d then owe tax on the difference between what you paid for the original stock and what you sell the new ETF for.

Holding indefinitely is also an option. If the new ETF goes into your estate, your heirs will inherit it at its market value on your date of death. That “step up” would effectively erase most of the long-term, capital-gains tax liability…

Under federal law, for you to be able to defer capital-gains tax in a 351, a single issuer’s stock can’t exceed 25% of the portfolio you contribute to the ETF, and five stocks can’t exceed 50% of your total. Cash doesn’t count in the calculations… [end quote]

Of course, anyone planning to use this should research it in more depth and discuss it with any tax or financial advisors.

Wendy

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Exchange contracts for diversification have been available for a while. Financial stability of the issuer has to be a concern. An ETF Looks like a better choice.

What is the ticker?

The article has more details.

There’s nothing to say the investor can’t buy an ETF, wait some time (30 days?) then sell it.

That’s why I said that anyone who is interested needs to look into this further. I don’t need this myself.
Wendy

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To me there are two essential elements.

  1. IRS agrees the transaction acquiring ETF shares meets 351 exchange requirements
  2. Financial stability of the firm holding your assets.

When those requirements are met this can be a useful way to diversify.

I’d be surprised if a 30 day holding sale did not incur capital gains taxes.

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Let’s say I bought ETF “XYZ” that meets 351 exchange requirements. Once I’m an owner of “XYZ,” can I turn around and sell it the next day for whatever the market will pay? Would the capital gain/ loss from that next-day sale be the only reportable event?

Wendy

I looked at it sometime back… not sure if your gains are < $10M. Instead, I started preparing my wife to be ready for the tax bill, and talking about booking around 5% of gains every year. These conversations are not going anywhere, the moment discussion gets to the tax we will be paying…

The joys of gains evaporate when you consider taxes.

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But why? The long term rate is only 10%. Much less than wage taxes. Do people expect a free lunch?

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Yes, if you can work down gains under low capital gains rates, why not.

If you are talking abt $10MM, that is difficult. Diversification and letting heirs inherit at stepped up basis can be best strategy. But you can also get stuck w 40% or more estate tax.

In reply to no particular person:

The way I see this strategy most often used is for employees that received a significant amount of their compensation (and now their net worth) in a single stock and have now left the company (or in some cases, still employed).

Think of all those newly minted SpaceX millionaires. They don’t want to realize all those gains but they also don’t want to be so heavily concentrated in a single stock. This is a way, over time, to both diversify and to reduce some of the tax lability.

Note, exchanges funds require you to be an accredited investor so this strategy is not available to all investors.

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Also replying to no one in particular, all this really does is allow you to change the form of ownership without triggering a taxable event. If you want to realize the gain, you still have to pay the tax when you sell the ETF.

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@McLovin1981 my understanding from the article is that the cost basis of the ETF would be the value on the day it is bought.

For example…
Bought ABC stock in, say, 1980 for $1,000.
Value in 2026, say, $1,000,000.

Exchange ABC stock for equivalent value in the ETF, XYZ.
The cost basis of XYZ is $1,000,000.
Sell XYZ in (say) a month for $1,000,050.

The capital gain is $50.
Tax is owed on $50 capital gain. If XYZ is sold for less, a capital loss is reported for tax.

That converts a capital gains tax on $999,000 into a capital gain of $50. Or possibly even a loss.

Wendy

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This is just another attempt to legalize tax avoidance.

OMG!! OMG!!! I’M SHOCKED! SHOCKED! THAT LAWYERS ARE COOKING UP TAX AVOIDANCE SCHEMES! Especially ones that can only be used by the very wealthy.

Like some METARs. Which is why I posted it here.
Wendy

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The article clearly states that the cost basis of the etf shares are the same as the cost basis of your original stock. The advantage of a 351 exchange is diversification. The tax rules are not magically suspended. You still retain the step up basis on death, whether it’s the original stock or the etf.

Jk

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@JimKredux thanks for the correction. I guess it was too good to be true.

Wendy

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Not if you’re booking a $1 MM capital gain. You’d be paying 20% plus the 3.8% Medicare tax and if you’re over 65 and on Medicare about $13,000 in IRMAA penalties for you and your spouse.

intercst

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These schemes allow you to diversify your portfolio without incurring a sale and capital gain. It would be attractive to a retiring corporate executive (or multi-millionaire engineer) with most of his net worth in company stock.

You’re delaying taxation. But you can eliminate it by holding to death and letting your heirs get the stepped up cost basis.

intercst

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First of all there is no 10% slap, it is 0%, 15%, & 20%. Also, your income, short-term gain, interest, dividends, if they are together above $50K for a single filer or 100 K MFJ, will push you into 15% bracket.

Not sure where you get this idea. I didn’t complain about taxes, rather when you factor taxes, it is not as joyful.

Dear Wendy,

I needed to see some math to dig my teeth into this. Thank you.

There’s another route to avoid those capital gains.

Make a charitable contribution with the appreciated stock. You don’t have to recognize the gain and you get a contribution deduction for the current FMV of the stock.

However, the deductible amount of your contribution is limited to 30% of your AGI rather than the usual 60% of AGI limit. Any excess can be carried over to the next 5 years - with the 30% limit still applying to the future years.

That’s even better than a sec. 351 exchange.

—Peter

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