---
title: "Seven Post lists an ETF meant to defer its clients' stock gains"
url: "https://etf.net/news/seven-post-lists-tax-deferral-etf-2026-11-11"
published_at: "2026-11-11T17:21:34.089Z"
updated_at: "2026-11-11T17:21:34.089Z"
byline: "ETF.net Research"
---

# Seven Post lists an ETF meant to defer its clients' stock gains

The tax treatment is not assured, a cash buyer does not get the deferral, and that buyer could later owe tax on gains that built up before they owned a share.

By ETF.net Research. Published Nov 11, 2026.

Seven Post Investment Office LP's Equity Partners ETF, LTEQ, began trading on the New York Stock Exchange on Tuesday, Nov. 10. The documents describe a contribution of stock meant to defer U.S. tax for the adviser's eligible clients under Section 351 of the Internal Revenue Code. A person who buys the shares for cash does not get that deferral.

Seven Post's disclosure brochure, dated Sept. 30, says the firm had offered eligible clients the chance to contribute equity securities for fund shares before the listing. The offer required the client's written authorization, and participation was voluntary. The same brochure says Seven Post's pay from the fund rises with assets, so the firm has a financial incentive to recommend the contribution.

The [prospectus](https://www.sec.gov/Archives/edgar/data/1618627/000199937126022328/lteq-497_100726.htm), revised Oct. 7, says the fund expects to acquire a material amount of assets that way. As of the brochure's Sept. 30 date, the fund had not begun operating and no client assets were in it. Neither document describes the contribution as completed.

Seven Post, a San Francisco adviser, had about $9.6 billion under management as of Dec. 31, 2025, the prospectus says. An executive investment committee of Ali Bastani, Bruce W. Bligh and Eldridge F. Gray makes the investment decisions. Exchange Traded Concepts, the sub-adviser, places the trades.

If the contribution qualifies, it would defer, but not eliminate, any unrealized gain on the contributed stock, the prospectus says.

"The treatment of the Contribution as a nonrecognition transaction under Section 351 of the Code is not assured."

No ruling from the U.S. Internal Revenue Service has been sought, and the prospectus says none will be. Shortly after the contribution, third-party legal counsel is to give the fund an opinion that it qualifies, based on representations from the contributors and the fund.

The contributor's tax basis carries over to the fund, the prospectus says, and that basis could be less than the securities' current fair market value. A taxable sale could then produce more capital gain, or less capital loss, than if the fund had bought the same shares for cash.

The prospectus says the fund intends to distribute any net realized capital gains at least annually, and that distributions are generally taxable. Someone who buys LTEQ for cash, and holds the shares in a taxable account, could therefore owe tax on gains that built up before they owned anything. There is nothing to distribute unless the fund sells the stock and the year produces a net gain.

The prospectus says the IRS and the U.S. Treasury Department released Revenue Ruling 2026-20 and Notice 2026-62 on Sept. 28.

The [ruling](https://www.irs.gov/pub/irs-drop/rr-26-20.pdf) is about one plan. An investor contributes appreciated securities to a new ETF. As part of that plan, the fund uses some or all of those securities to redeem shares held by an authorized participant, the firm that creates and redeems shares directly with an ETF.

The ruling holds that the investor is treated as making a taxable exchange with that firm of the securities used in the redemption, rather than a tax-deferred contribution of them under Section 351.

The [notice](https://www.irs.gov/pub/irs-drop/n-26-62.pdf) describes strategies to diversify a portfolio without recognizing built-in gains, and calls them abusive. It says the IRS may challenge such a strategy on examination. Any further guidance could apply to transactions that have already taken place.

The notice also says it does not address, and expresses no view on, seeding a new ETF with assets that fit its investment approach and that the fund intends to keep, absent a substantial change in circumstances, including an unexpected change in market or business conditions. The IRS has not said that pattern qualifies.

The prospectus says the fund believes its contribution is distinguishable from the transactions in the ruling and the notice. The securities will match the portfolio it contemplates, and the fund has no plan to distribute them to an authorized participant in redemption of its shares. The same passage says the IRS or the Treasury may disagree.

The mandate is wide, and it leans to the United States. The fund seeks long-term capital appreciation. Under normal conditions it will invest at least 80% of net assets, plus any borrowings for investment purposes, in equity and equity-related securities of U.S. and non-U.S. issuers. It seeks to invest at least 70% of net assets in U.S.-domiciled securities. It may own any size company, in any country.

None of that portfolio is public. The [issuer's website](https://equitypartnerfunds.com/), which dates inception to Nov. 10, leaves assets, holdings and net asset value blank. On Tuesday, 2,132 shares changed hands.

## What a cash buyer already pays elsewhere

The prospectus lists total annual operating expenses of 0.71%, and **0.61%** after a waiver that runs through Dec. 31, 2027. Seven Post has agreed to limit the management fee to 0.55%, from 0.65%, through that date. The limit cannot end early without approval from the board of The RBB Fund Trust, which issues the fund.

That net fee is higher than the charge on each of the three funds below. None of them is the same product.

JPMorgan Asset Management's JPMorgan Global Select Equity ETF, JGLO, invests primarily in large-cap stocks in developed markets. Its [Sept. 30 fact sheet](https://am.jpmorgan.com/content/dam/jpm-am-aem/americas/us/en/literature/fact-sheet/etfs/FS-JGLO.PDF) shows expenses of 0.47%, gross and net. Assets were $6.41 billion.

Fiduciary Management's FMI Global Equity ETF, FMIG, began trading Nov. 5, five days earlier. Its [Nov. 3 prospectus](https://www.sec.gov/Archives/edgar/data/1023391/000199937126024329/fmig-497k_110326.htm) requires at least 30% of assets in non-U.S. companies under normal circumstances, and at least 20% if the adviser finds those markets less favorable. That minimum is close to the reverse of the new fund's aim of at least 70% in U.S.-domiciled securities. It invests mainly in a limited number of large-cap stocks, generally of $4 billion or more, and lists net expenses of 0.55% through at least Jan. 31, 2028.

American Century Investment Management's Avantis All Equity Markets ETF, AVGE, is a fund of other Avantis stock funds. Its [prospectus](https://www.sec.gov/Archives/edgar/data/1710607/000171060726000204/acetftavge497k.htm), revised Aug. 1, sets a target weight of 70% in U.S. equity, in a range of 63% to 77%. Total annual expenses are 0.23%.

For a person buying with cash, the structure does not help. The deferral, if the contribution qualifies, runs to the investor who hands over the stock. A cash buyer could be taxed on gains that built up in that stock, and the net fee is higher than what these three already charge, for a portfolio the website does not yet show.

Source: etf.net, https://etf.net/news/seven-post-lists-tax-deferral-etf-2026-11-11. Please cite the page URL.
