1 rich Libsyn https://www.libsyn.com 90 600 What happens when a widely used tax strategy suddenly comes under IRS scrutiny? For advisors working with clients who hold concentrated stock positions, that question has become very real. In this joint episode of the PFP Podcast and Tax Section Odyssey, Cary Sinnett talks with nationally recognized tax expert Bob Keebler about recent IRS guidance affecting certain Section 351 ETF conversion strategies. They discuss how the step transaction doctrine may apply, why some previously completed transactions could face scrutiny, and what advisors should be doing now for clients who have used or are considering these strategies. What You'll Learn Why the IRS is focusing on transactions that combine a Section 351 contribution with a rapid ETF redemption How timing can influence whether multiple steps are viewed as independent transactions or a single integrated plan What characteristics may increase scrutiny, including prearranged diversification strategies and marketing materials What advisors should consider when reviewing clients who have already completed a Section 351 ETF conversion Why documentation, professional guidance, and penalty protection may become increasingly important as these transactions are challenged Practical Takeaway Review any client Section 351 ETF conversions with a focus on timing, documentation, and transaction structure. For clients with significant exposure, consulting a tax specialist before filing may help clarify risks and reporting positions. More broadly, this episode serves as a reminder that advisors add value by looking beyond the promised tax outcome and evaluating whether a strategy's substance supports its intended tax treatment. AICPA Resource Resource: Section 351 Resource Podcast: How CPAs Are Shaping the Future of Financial Planning with Jimmy Williams Resource: Planning after tax changes Resource: Prudent Practices for Investment Advisors and Investment Stewards This episode is brought to you by the AICPA’s Personal Financial Planning Section, the premier provider of information, tools, advocacy, and guidance for professionals who specialize in providing tax, estate, retirement, risk management and investment planning advice. Also, by the CPA/PFS credential program, which allows CPAs to demonstrate competence and confidence in providing these services to their clients. Visit us online to join our community, gain access to valuable member-only benefits or learn about our PFP certificate program. Subscribe to the PFP Podcast channel at Libsyn to find all the latest episodes or search “AICPA Personal Financial Planning” on your favorite podcast app. AICPA Personal Financial Planning (PFP) https://pfplanning.libsyn.com/pfp <iframe title="Libsyn Player" style="border: none" src="//html5-player.libsyn.com/embed/episode/id/43315849/height/90/theme/custom/thumbnail/yes/direction/forward/render-playlist/no/custom-color/88AA3C/" height="90" width="600" scrolling="no" allowfullscreen webkitallowfullscreen mozallowfullscreen oallowfullscreen msallowfullscreen></iframe> https://assets.libsyn.com/secure/item/43315849