Tax Efficiency
ETFs provide in-kind redemption benefits, which can significantly reduce capital gains impact.
Operational Simplicity
Eliminate the burden of individual account management.
Scalability
Reach a wider audience via exchange-traded access with lower operational friction.
IRS rules require strict diversification — no single asset can exceed 25% of total value and holdings over 5% must stay under 50% collectively. Tidal’s portfolio review process helps to ensure your assets meet these standards ahead of launch, protecting your conversion’s tax-free status.
To qualify under Section 351, original contributors must retain at least 80% control of the ETF immediately post-conversion. Tidal structures your transaction to preserve this ownership threshold while setting your fund up for future scale.
Precise documentation of cost basis and holding periods is critical for future tax reporting. Tidal manages the complete transfer and recordkeeping process, aiming to ensure compliance from day one and positioning your ETF for potential future operational excellence.
Diversification Compliance
We pre-review your portfolio to meet IRS standards — no guesswork, no surprises.
Ownership Structuring
We design your conversion to maintain 80% control, qualifying your transaction for tax-free status.
Complete Recordkeeping
Cost basis, holding periods, transfer logistics — handled seamlessly and accurately.
Regulatory & Operational Experience
Filings, legal, listings, market makers — we cover it all so you don’t have to.
Launch Operations
From first step to first trade, our team aims to ensure a flawless transition.
When you choose Tidal, you gain far more than administrative support — you gain a strategic partner who knows how to navigate every stage of a complex 351 conversion.
At Tidal, we strive to remove the complexity, allowing you to focus on what matters most: delivering exceptional strategies to a broader investor base.
Tidal Financial Group is an award-winning, full stack ETF platform enabling financial institutions to launch, manage, trade and grow your ETFs.