As financial advisors and their clients learn more about the potential tax advantages of a Section 351 ETF conversion, a new website aims to connect issuers with investors.

351conversion.com founder Matt Bucklin “cannot make money” through “transaction fees or anything like that” by providing advisors, investors and ETF issuers with informational resources and possible products to use in an increasingly popular asset migration method named for a provision of the Tax Code enabling exchanges of similar products. Securities and Exchange Commission rules from 2019 and 2020 for active management of ETFs, along with the development of financial technology, have led to a bumper crop of products offering tax deferral for investors with low-basis stocks and separately managed accounts.

“It could be a great time to diversify out of certain highly appreciated securities,” Bucklin said in an interview. He promised not to “bombard” people who sign up on his website with emails but simply “put them in touch with the ETF issuer” if a new product fitting their preferences is coming to market. “I have done a lot of online marketing, ecommerce and things, and I’ve never put up a website that gets ranked organically on Google,” Bucklin added.

READ MORE: How to unlock tax savings in incoming client portfolios

Bucklin came up with the idea for the site when he was speaking with Wes Gray, the founder of technology and asset management firm ETF Architect and an innovator in the approach. An influx of new products may obscure how the tool for deferring, rather than avoiding, capital gains distributions could create “a little bit more tricky scenario” if the issuer is, for example, not using sophisticated management of the tax lots in an ETF based on the differing needs of seed and second-day investors or ensuring their choice to do the conversion is “in line with how you expect your funds to be managed on the forward,” said Brittany Christensen, the senior vice president of business development for ETF service and technology firm Tidal Financial Group.

“Everyone wants the easy, ‘I’m out of all my Nvidia, and I don’t have to pay taxes on it,'” she said. “There are also other factors to consider before really making the decision to go down that path. The solicited transactions are a relatively new phenomenon and might be hitting some people’s inboxes with these marketing campaigns.”

The rules carry requirements about the level of stock concentration in the incoming assets and the need for the strategies to be the same on both sides of the transition. 

So far, the website links investors to just one product, but more are on the way, Bucklin noted. The fact that the SEC “has never gone after anyone for doing a 351 conversion yet” and the availability of “insurance protection from tax liability” show that advisors and clients who abide by the guidelines are taking a relatively low risk of regulatory pushback against the exchange, he said, crediting Gray with championing the strategy. New ETFs frequently must overcome a classic catch-22 in which they need to attract $50 million in investments to access large wealth management firms’ menus but struggle to find that seeding without being on the giant platforms.

“A lot of ETFs have launched with nothing and just hoped to gather assets, and it’s just really tough to get to $50 million,” Bucklin said. “I’ve seen some great strategies that just get stuck.”

READ MORE: 2025 wealth management trends: Private equity, new ETF debuts

As more products hit the shelf, advisors and clients should keep in mind that they “could have contributions with exposure to double tax” if the issuer and their service providers fail to account for distributions affecting early and later investors, Christensen noted. She finds that “very few people” grasp that difficulty and the need to work with an outside firm to avoid it, she said. Otherwise, they may not be able to tap into the full benefits of a 351 conversion.

“I’m probably a little nervous right now with what’s going on in the ETF space if I’m not actively trying to get into that world,” she said. “It’s a win-win for everyone and allows a newcomer to start with a ‘bring your own assets’ type of strategy. Their clients are already comfortable with how they’re investing their money.”

Berkshire Hathaway Inc. Chairman Warren Buffett said the company has paid the U.S. government more than $101 billion in taxes since he took the helm 60 years ago, more than any other firm in history, according to his annual letter to investors on Saturday. 

Buffett’s comments come as President Donald Trump has vowed to cut corporate taxes further after slashing them to 21% during his first term in 2017. Trump wants to reduce the corporate tax rate to 15%.

Berkshire paid $26.8 billion in taxes in 2024 alone. Buffett said that “record-shattering” figure amounts to roughly 5% of the total taxes paid by U.S. companies last year, and excludes state taxes and taxes paid to foreign governments.

“If Berkshire had sent the Treasury a $1 million check every 20 minutes throughout all of 2024 — visualize 366 days and nights because 2024 was a leap year — we still would have owed the federal government a significant sum at yearend,” Buffett wrote. 

Berkshire’s 2024 tax bill exceeded that of the previous five years combined, owing in part to his significant sales last year of two of its biggest holdings, Apple Inc. and Bank of America Corp., according to Edward Jones analyst Jim Shanahan.

“He’s boasting about taxes, but it’s kind of an unusual year,” Shanahan said. “I don’t know if he was specifically trying to call out large tech companies that don’t pay much in terms of cash taxes, but certainly if I’m reading between the lines, that’s what I’m seeing.”

Cathy Seifert, an analyst at CFRA, interpreted the comments in a similar way.

“I think the underlying message is: ‘Don’t lump every multibillion-dollar corporation as even; some pay their fair share of taxes’,” Seifert said in an interview. 

Berkshire reported on Saturday that its operating profits for the fourth quarter surged 71%, driven by a nearly 50% jump in insurance investment income and improvement in its insurance underwriting business. Its annual operating earnings rose to $47.4 billion, up nearly 27% from the previous year. 

Vast conglomerate

In the annual letter, Buffett said that when he took control of the Berkshire Hathaway company in 1965, it was a struggling textile operation that paid zero in income taxes that year, and hadn’t for much of the previous decade.

“That sort of economic behavior may be understandable for glamorous startups, but it’s a blinking yellow light when it happens at a venerable pillar of American industry,” Buffett wrote. “Berkshire was headed for the ash can.”

Today, Berkshire Hathaway is a vast conglomerate spanning more than 189 operating companies, a public equity portfolio worth $272 billion and a cash pile worth $334 billion as of the end of 2024, according to the annual report. Buffett said the company’s success is due in large part to America’s capitalist economy, a system that he said has its faults — “in certain respects more egregious now than ever” — but also “can work wonders unmatched” by other models. 

Buffett also credited Berkshire’s investors for foregoing dividends to reinvest their income, noting that the company only paid investors one dividend, in 1967. He said he couldn’t recall why he suggested the move to Berkshire’s board, a decision he said “seems like a bad dream.”

Buffett addressed part of the letter to “Uncle Sam.”

“Someday your nieces and nephews at Berkshire hope to send you even larger payments than we did in 2024,” he wrote. “Spend it wisely. Take care of the many who, for no fault of their own, get the short straws in life. They deserve better.”

Seifert called the comments “a subtle yet important swipe” at the current political environment.

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The pricing of accounting services is a big concern and it should be. My definition of pricing services properly is that if, at the end of the year, you’ve made your living, funded your retirement account, and had money left over to maintain and build your infrastructure, you’re pricing your services OK. If you have something left over after that, then good for you, you are doing it right and you should enjoy that profit. But the minimum is the first three things.

I get frequent calls about this. My advice is to increase fees at a uniform percentage to make up for the shortfall going forward. Here is how to go about this.

The first step is to calculate the shortfall. By way of illustration assume you are grossing $250,000 and have a $30,000 shortfall. $30.000 ÷ $250,000 = 12%. This means your fees need to be increased 12% in total. This assumes these are your numbers for the current year. If these are last year’s numbers, then project your shortfall for the current year and use that. 

The second step is to increase the fees for every client immediately by 12%. If you have contracts, you might not be able to do this, but if you have an arrangement that doesn’t lock you into a price no matter what, then increase those clients, which should be most of your clients. If the contractual fees are substantial, then factor that in and you might need a larger percentage increase than the across-the-board calculation.

The third step is to start contacting your larger or more important clients. Start with them but plan on contacting every client. I personally call everyone. They all pay your salary, so make the call. If they were a new client, you would do somersaults to get them. Here, all you need to do is call them. I suggest telling them something similar to this:

“I regret that I have to increase my fees with you. My overall fees are too low and I am not making what I need to provide my living, fund my retirement account and have sufficient funds to maintain my practice with needed maintenance, technology changes and technical update notifications. Accordingly, as much as I hate to do this, I am forced to increase the fees for all of my clients 12% effective the first of next month. This is not something I like to do, but I have to do it so I can continue the level of services my clients are accustomed to and deserve. This is the only way that makes sense. I know you will understand, and if you want to think about it and have another discussion, please call me. I appreciate you being a client and know we will continue our successful collaboration.”

I used an illustrative amount, but this method works for any size practice, from a solo to a large multioffice practice. The reality is that if there is a shortfall, this needs to be done. 

Alternatives like getting more business is a way to grow your practice, but at your present level with the shortfall from your established clients and existing workload, the issue isn’t growth but maintaining the status quo. Being immersed in tax season means now is not a good time, but neither is any other time. Delaying this inevitable action will just make the situation worse. You are a businessperson and need to act like one and your revenues need to reflect this.

Do not hesitate to contact me at [email protected] with your practice management questions or about engagements you might not be able to perform.