351 exchange intro call — fifteen minutes.
351 ETF EXCHANGE
Do you seek an advisor for access and to help you navigate your options with appreciated stock?
For investors with appreciated portfolios weighing a 351 exchange — to determine mutual fit. Find a time that works for you. We will confirm the appointment personally.
What decides whether it fits
- What you contribute has to be diversified. Broadly, what you contribute must pass the diversification tests: at most 25% in one issuer and 50% in the five largest combined. A single concentrated stock generally can't be contributed on its own.
- You can contribute only when a fund launches. Contributions are accepted only at a fund's launch or during its contribution window.
- The gain is deferred, not eliminated. Your cost basis carries over, and the deferred gain comes due when you sell the ETF shares.
- A fully transparent exchange. You can expect Schwab to carry each lot's basis and holding period into the ETF shares it became.
- Not everything qualifies. Mutual funds, CEFs, restricted or pledged holdings and most derivatives generally can't be contributed.
- What the IRS is watching. Under IRS guidance from September 2026, a contribution that passes the tests can still be taxed if the fund plans to redeem your securities out to a market maker and hold a different portfolio.
General information about how the exchange works — not tax or legal advice. Eligibility depends on the fund and on the securities you contribute; confirm your own situation with your tax advisor.
The full 351 explainer