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First Horizon Employees: Strategic Ways to Reduce Capital Gains on Appreciated Stock

Healthcare Provider Update: First Horizon offers health, dental, and vision insurance tailored to individual and family needs. Employees benefit from HSAs, FSAs, disability coverage, and parental leave. The company provides a 401(k) with up to 6% matching, adoption reimbursement, and wellness programs. Additional perks include tuition reimbursement, mentoring, and digital wellness platforms3. First Horizon With ACA premiums projected to rise sharply, First Horizons employer-sponsored plans and financial wellness tools help employees avoid the volatility of marketplace costs. Their matched savings and flexible spending options provide a buffer against rising healthcare expenses. Click here to learn more

'First Horizon employees can benefit from understanding that strategies like a Section 351 exchange, charitable donations, and tax loss harvesting may work together to help manage appreciated stock efficiently while aligning with broader long-term financial goals.' – Tyson Mavar, a representative of The Retirement Group, a division of Wealth Enhancement.

'First Horizon employees should recognize that thoughtful planning with tools such as Section 351 exchanges, gifting strategies, and tax loss harvesting can help them manage highly appreciated stock while supporting both personal and philanthropic objectives.' – Wesley Boudreaux, a representative of The Retirement Group, a division of Wealth Enhancement.

In this article we will discuss:

How a Section 351 exchange can defer capital gains on highly appreciated stock.
Alternative tax-efficient strategies such as charitable donations, tax loss harvesting, and gifting.
The role of inheritance rules, step-up in basis, and combined approaches in long-term tax planning.

A Tax-Aware Q&A on How to Manage Highly Appreciated Stock

From the Section 351 exchange to other practical approaches, this Q&A addresses key considerations First Horizon employees may encounter when dealing with highly appreciated shares.

Section 351 Exchange: The Fundamental Approach

Q: What is an exchange under Section 351?
A: Under certain circumstances, an investor may transfer property, such as highly appreciated shares, to a company in exchange for its stock under a provision of the Internal Revenue Code that allows the deferral of capital gains or losses.

Q: What is the primary advantage of exchanging my appreciated stock through a Section 351 exchange?
A: The main advantage is tax deferral. Gains transferred to corporations may be postponed under Section 351, though this applies only if specific diversification requirements are met, especially when transferring to investment companies like exchange-traded funds (ETFs). ¹

Q: What is meant by the “Control Test”?
A: The investor or group of investors who use their portfolio assets to fund the new entity must own at least 80% of the voting power and 80% of the total number of shares of all other classes of stock in the new company immediately after the exchange. ¹

Q: When seeding an ETF, how is the Control Test usually satisfied?
A: It is typically satisfied by either a single substantial investor making a significant asset contribution or multiple investors pooling assets to create a seeding pool for the ETF’s launch.

Q: What is the ultimate tax payment date for the deferred gain?
A: The deferred gain is recognized when the ETF shares acquired through the exchange are sold; distributions from taxable funds must also be reported in the meantime.

Other Tax-Efficient Techniques

Q: What is a straightforward method, aside from a Section 351 exchange, to sell highly appreciated shares without incurring large taxes?
A: Donating shares directly to a qualified charity is one option that some First Horizon employees may benefit from.

Q: What tax advantages come with donating valuable stock to a charity?
A: Subject to holding period and adjusted gross income (AGI) limits, you can bypass capital gains taxes on the appreciation and may receive an income tax deduction for the stock’s full fair market value.

Q: What is a Donor-Advised Fund (DAF)?
A: A DAF allows you to donate appreciated stock, receive an immediate tax deduction, and then recommend grants to charities over time, while the assets in the DAF grow without tax impact. ²

Q: Can I give a family member my appreciated stock as a gift?
A: Yes. In most cases, the cost basis from the donor carries over to the recipient.

Q: Why would I give a family member in a lower tax bracket appreciated stock?
A: If they sell the stock, the lower income could result in a reduced capital gains rate, potentially as low as 0% for long-term gains. ³

Tax Loss Harvesting and Other Approaches

Q: What is harvesting tax losses?
A: Selling investments at a loss to offset gains from other sales is known as tax loss harvesting, a strategy sometimes considered by First Horizon employees seeking opportunities to leverage bouts of market volatility.

Q: Can I deduct a certain amount of loss from my regular income?
A: Yes. If your capital losses exceed your gains, you can use up to $3,000 per year ($1,500 if married filing separately) to offset ordinary income, with remaining losses carried forward indefinitely. ⁴

Q: What is a Qualified Opportunity Fund (QOF)?
A: A QOF provides investors with tax incentives for investing in tracts of land designated as 'opportunity zones'. Capital gains reinvested in a QOF within 180 days of being realized can be temporarily tax deferred, while QOF investments helpd for at least 10 years may confer a permanent capital gains exclusion. ⁵ That said, 2025 legislation changes may prompt IRS updates to this rule.

Inheritance and Step-Up in Basis

Q: What is meant by a “step-up in basis”?
A: This adjusts an inherited asset’s cost basis to its fair market value at the time of the owner’s death, eliminating capital gains accumulated during their lifetime. ⁶

Q: If I gift shares while living, will I receive a step-up in basis?
A: No. The original cost basis transfers to the recipient without adjustment.

Determining the Right Strategy

Q: What is the best course of action for me?
A: The most suitable approach will depend on factors such as your gain size, income level, charitable intentions, and liquidity needs.

Q: Do any of these strategies call for professional guidance?
A: Yes. Given the complexity of the tax code, working with a qualified financial advisor and tax professional is strongly recommended before implementing these strategies.

Q: Is it possible to combine these strategies?
A: Yes. For example, you might execute a Section 351 exchange on part of your portfolio for tax-deferred rebalancing while donating another portion to a DAF for an immediate deduction.

Q: Is there a loophole in the Section 351 exchange?
A: No. This is a legitimate tax code provision designed for corporate restructuring and adapted for use in the ETF market. It is intended for tax deferral, not permanent tax elimination.

Featured Video

Articles you may find interesting:

Sources:

1. Kitces. ' Using Section 351 Exchanges to Tax-Efficiently Reallocate Portfolios With Embedded Gains ,' by Ben Henry-Moreland and Brent Sullivan. 12 Mar. 2025.

2. Kiplinger. “ A Donor-Advised Fund Can Give Your Charitable Giving a Boost ,” by Samuel Gaeta. 9 May 2024.

3. Internal Revenue Service. “ Topic No. 409, Capital Gains and Losses .” IRS.gov , 8 July 2025.

4. Wealth Enhancement. ' 6 Essential Tax-Loss Harvesting Tips ,' by Jim Wiley. 6 April 2022.

5. Congressional Research Service. ' Tax Incentives for Opportunity Zones ,' by Donald Marples. 26 Apr. 2022.

6. Investopedia. “ Carryover Basis: What It Is, How It Works, Gift Taxes ,” by Julia Kagan. 16 Jan. 2023.

What type of retirement savings plan does First Horizon offer to its employees?

First Horizon offers a 401(k) retirement savings plan to help employees save for their future.

Does First Horizon provide matching contributions to the 401(k) plan?

Yes, First Horizon provides a matching contribution to the 401(k) plan, which helps employees maximize their retirement savings.

What is the eligibility requirement to participate in First Horizon's 401(k) plan?

Employees at First Horizon are eligible to participate in the 401(k) plan after completing a specific period of service, typically within the first year of employment.

How can employees at First Horizon enroll in the 401(k) plan?

Employees can enroll in First Horizon's 401(k) plan through the company’s HR portal or by contacting the HR department for assistance.

What investment options are available in First Horizon's 401(k) plan?

First Horizon offers a variety of investment options in its 401(k) plan, including mutual funds, target-date funds, and other investment vehicles.

Can employees at First Horizon take loans against their 401(k) balance?

Yes, First Horizon allows employees to take loans against their 401(k) balance under certain conditions, as outlined in the plan documents.

What is the vesting schedule for First Horizon's 401(k) matching contributions?

The vesting schedule for First Horizon's matching contributions typically follows a graded schedule, which means employees earn ownership of the match over a period of time.

Are there any fees associated with First Horizon's 401(k) plan?

Yes, there may be administrative fees associated with First Horizon's 401(k) plan, which are disclosed in the plan documents.

How often can employees at First Horizon change their 401(k) contribution amount?

Employees at First Horizon can change their 401(k) contribution amount at any time, subject to the plan's guidelines.

What is the maximum contribution limit for First Horizon's 401(k) plan?

The maximum contribution limit for First Horizon's 401(k) plan is set by the IRS and may change annually; employees should refer to the latest IRS guidelines for specifics.

With the current political climate we are in it is important to keep up with current news and remain knowledgeable about your benefits.

First Horizon National Corporation offers both a pension plan and a 401(k) plan to its employees. The First Horizon National Corporation Pension Plan is a defined benefit corporate pension fund that was established in 1946. This pension plan provides retirement, death, and disability benefits to eligible employees and their beneficiaries. The assets of the pension plan are managed by the Pension, Savings, and Flexible Compensation Committee, with First Tennessee Bank National Association serving as the trustee (PitchBook). In addition to the pension plan, First Horizon provides a 401(k) plan where employees can save for retirement with contributions matched by the company up to 6% of their pre-tax income. The 401(k) plan also includes various savings and money management tools, such as Health Savings Accounts (HSA) and Flexible Spending Accounts (FSA), which allow employees to set aside pre-tax income for healthcare and dependent care expenses

Restructuring and Layoffs: In early 2024, First Horizon announced a significant restructuring plan aimed at streamlining operations and reducing costs. The bank plans to cut approximately 5% of its workforce over the next year as part of this initiative. This move is in response to increasing operational expenses and the need to enhance efficiency in a challenging economic environment. This news is particularly relevant as it reflects broader trends in the banking sector where institutions are adjusting their workforces to remain competitive amidst economic uncertainty.

First Horizon Corporation (FHN) provides a comprehensive employee stock option and Restricted Stock Unit (RSU) program aimed at retaining top talent and incentivizing long-term performance. First Horizon offers both stock options and RSUs to eligible employees, primarily those in executive or senior management roles. These awards generally vest over a period of three to five years, with specific performance metrics tied to company performance and stock price. Employees who meet certain job levels and performance criteria are eligible to participate in these equity compensation plans. In 2022, First Horizon offered RSUs that vest annually, providing employees with ownership stakes in the company. By 2023 and 2024, the bank continued this program with slight adjustments, including expanded eligibility and adjusted performance criteria (

First Horizon Health Benefits Overview Company Website: The official First Horizon website provides the most direct and accurate information. Glassdoor: This site often has employee reviews and details about health benefits, including recent changes or feedback from employees. Indeed: Similar to Glassdoor, Indeed might have employee reviews and specific information about health benefits and any recent updates. LinkedIn: Sometimes companies post updates about employee benefits or changes in health-related policies here. Benefits.gov: This site provides general information about employee benefits and might have relevant details or changes affecting First Horizon.