定義
A private partnership that allows multiple investors to contribute appreciated shares and receive diversified fund interests in return, potentially deferring the capital-gains tax that an outright sale would trigger.
An exchange fund — sometimes called a swap fund — pools low-basis stock from many contributors into a single partnership. Each contributor exchanges their concentrated shares for a pro-rata interest in the fund, which now holds a diversified basket of securities. Because no shares are technically sold, the immediate capital-gains event that a direct sale would create may be deferred. The mechanics, eligibility rules, and holding-period requirements are governed by tax law, and a qualified attorney and CPA must evaluate whether a specific situation qualifies.
These structures are generally available only to accredited investors meeting substantial net-worth thresholds, which makes them most relevant at the wealth levels discussed in resources like Wealth at $50 Million and beyond. Illustratively, a technology executive holding a single stock worth several million dollars with a near-zero cost basis might contribute those shares to an exchange fund rather than sell outright and face a large immediate tax bill.
A common confusion is assuming an exchange fund eliminates tax permanently — it does not. The deferred gain generally carries over into the fund interest and becomes due eventually upon redemption or sale. Liquidity is also limited; funds typically impose multi-year lock-up periods. Exchange funds are explored further in the main article on exchange funds, and families often evaluate them alongside hedging and collars and concentrated stock positions strategies.
最終レビュー日 August 25, 2026 · 編集方針
