New Update: Healthcare Costs Increasing by Over 60% in Some States. Will you be impacted?

Tax Strategies for Genuine Parts Employees With Concentrated Stock Positions

For Genuine Parts employees who have experienced significant market appreciation, the thought of rebalancing their portfolio can be daunting. The large embedded capital gains in their holdings often create a powerful disincentive to sell, leading to a 'tax-locked' portfolio. While an investor may have a well-diversified portfolio on the whole, a single, highly appreciated stock can still represent an uncomfortable level of risk. In these situations, the conventional wisdom of simply selling the position is often prohibitively expensive from a tax perspective. However, a little-known but powerful tool—the Section 351 exchange—may offer a strategic and tax-efficient solution.

Consider Michael, a successful professional with a total investment portfolio of $5 million. The majority of his assets are in a broadly diversified mix of mutual funds and exchange traded funds (ETFs). However, his portfolio also includes a single stock position valued at $500,000, which he acquired years ago for $100,000. While this single stock represents only 10% of his total portfolio, its low cost basis and unrealized gain of $400,000 make him hesitant to sell. A sale would trigger a tax bill of roughly $95,200, reducing the capital available for reinvestment and diversification. Michael's situation is common; he understands the importance of diversification, but the tax cost of achieving it feels punitive.

This is precisely the kind of scenario where a Section 351 exchange can provide a strategic advantage. This tax provision, as outlined in the Internal Revenue Code, allows for a tax-deferred transfer of property to a corporation in exchange for its stock, provided certain conditions are met. As Kevin Landis, a finanial advisor with Wealth Enhancement notes, 'A Section 351 exchange could help investors with appreciated assets achieve tax-efficient diversification.'

The core of the strategy is rooted in the tax code itself. IRC Section 351(a) states: “No gain or loss shall be recognized if property is transferred to a corporation by one or more persons solely in exchange for stock in such corporation and immediately after the exchange such person or persons are in control (as defined in section 368(c)) of the corporation.” The gain is not eliminated, but deferred, as the investor's original cost basis carries over to the new corporate shares. This is a critical distinction from a traditional sale.

For the exchange to be valid, two main requirements must be satisfied:

Diversification: The portfolio being transferred must be diversified according to the IRS's 25/50 test. This means no single holding can represent more than 25% of the total value, and the top five holdings cannot exceed 50%. Since Michael's $500,000 single stock position is only 10% of his total $5 million portfolio, his entire portfolio passes this test.

Control: The investor must have at least 80% control of the newly formed corporation immediately following the exchange. In practice, this is often achieved by multiple 'seeding' investors transferring assets at the same time to establish an ETF, or by an investor with a significant enough portfolio acting as the primary seeder of a new fund.

By working with an ETF sponsor that facilitates these exchanges, Michael can transfer his entire $5 million portfolio into a newly formed ETF. He would receive ETF shares in return, and his $400,000 unrealized gain would not be taxed. Within the ETF wrapper, the fund manager could then sell Michael's single stock and reinvest the proceeds into other securities to align with the fund's mandate. Due to the in-kind creation and redemption process of ETFs, this internal rebalancing does not trigger a taxable event for Michael. He has successfully diversified away from his single-stock risk and preserved the full $500,000 of market value.

Tyson Mavar, a Senior Vice President and Financial Advisor with Wealth Enhancement, emphasizes the importance of a holistic approach to these complex strategies. 'For clients with significant embedded gains, the goal is always to optimize after-tax returns,' Mavar says. 'A Section 351 exchange is a prime example of a strategy that, when executed correctly, can help preserve capital that may otherwise be lost to taxes, allowing it to continue working for the client over the long term.'

While the benefits are clear, it's important to acknowledge the limitations. The number of ETFs currently accepting such exchanges is limited, and these funds may have higher expense ratios than their more established counterparts. There's also the risk of an inadvertent tax treatment failure if the rules are not strictly followed. However, for an investor like Michael, the ability to defer a substantial tax bill and gain immediate diversification makes the strategy compelling. It is a powerful tool for advisors to help their clients escape the 'tax-locked' state and realign their portfolios with their long-term financial goals.

Key Resources:

IRC Section 351(a): https://www.law.cornell.edu/uscode/text/26/351

IRS Treasury Regulation 1.351-1(c)(5): This regulation details the diversification test, often referred to as the 25/50 test, which is crucial for the strategy to be valid.

Kitces.com: 'Using Section 351 Exchanges To Tax-Efficiently Reallocate Portfolios' by Ben Henry-Moreland (March 12, 2025). This article provides a comprehensive overview of the strategy's mechanics and use cases.

Cambria Tax Aware ETF (Ticker: TAX): As one of the first ETFs to publicly announce the use of Section 351 exchanges, its prospectus and fund information offer a real-world example of the strategy in practice.

Longview Advantage ETF (Ticker: EBI): Another example of a new fund launched via Section 351, demonstrating the increasing adoption of this strategy by ETF sponsors.

Other ideas if you own a highly appreciated stock

Featured Video

Articles you may find interesting:

- Donating highly appreciated stock to a public charity.

- Contributing appreciated stock to a Donor-Advised Fund (DAF).

- Gifting highly appreciated stock to a family member in a lower tax bracket.

- Upstream gifting of appreciated stock to an older family member for a step-up in basis.

- Using tax-loss harvesting to offset capital gains.

- Entering into a variable prepaid forward contract.

- Reinvesting capital gains into a Qualified Opportunity Fund (QOF).

- Holding the stock until death to receive a step-up in basis for heirs.

What benefits does the GPC Pension Plan provide to employees of Genuine Parts Company, and how are these benefits calculated for both Group 1 and Group 2 employees? In the context of Genuine Parts Company, what are the critical factors that determine the pension benefits for employees and how have recent changes to the plan affected these calculations?

The benefits of the GPC Pension Plan for Genuine Parts Company employees are calculated based on the employee’s Final Average Monthly Earnings (FAME) and years of Credited Service. For Group 1 employees, benefits are frozen as of December 31, 2013, with the FAME calculated from the five highest-paid years within the last ten years of service before that date. For Group 2 employees, benefits are similarly frozen as of December 31, 2008, and the same calculation of FAME is applied using the highest earnings before that freeze date(Genuine Parts Company_P…).

How do the eligibility requirements of the GPC Pension Plan differ between Group 1 and Group 2 employees at Genuine Parts Company? Additionally, what specific service requirements must employees meet to qualify for the benefits under each group, particularly considering the impact of employment history and rehire status on benefits?

Eligibility requirements differ between Group 1 and Group 2 employees. Group 1 includes employees with Rule of 70 status, who opted to continue participation in the plan after January 1, 2009. Group 2 employees, which include those rehired before December 31, 2013, had their Credited Service frozen earlier in 2008. Group 1 employees have Credited Service frozen as of December 31, 2013, while Group 2’s freeze date is December 31, 2008(Genuine Parts Company_P…).

What strategies can employees of Genuine Parts Company consider for optimizing their pension benefits when transitioning to retirement? Are there specific actions that employees should take prior to retirement to enhance their benefit calculations under the GPC Pension Plan, particularly in relation to Credited Service and Final Average Monthly Earnings?

To optimize pension benefits, Genuine Parts Company employees should focus on maximizing Credited Service and Final Average Monthly Earnings (FAME). Ensuring a full work history before the freeze date (2013 for Group 1, 2008 for Group 2) can enhance the benefit calculation. Employees can also review their Social Security benefit estimates, which are considered in calculating their pension(Genuine Parts Company_P…).

How does the vesting process work for employees participating in the GPC Pension Plan at Genuine Parts Company, and what implications does it have for those contemplating early retirement? Furthermore, how does the ability to vest at different service intervals specifically impact the retirement planning of employees?

The vesting process for the GPC Pension Plan requires employees to accumulate vesting service years, which continues even after the freeze date. Employees are automatically fully vested after seven years of service, or if they worked at least one hour after December 31, 2013. Vesting ensures the right to the earned pension benefits, which may affect retirement planning, especially for those contemplating early retirement(Genuine Parts Company_P…).

What information should Genuine Parts Company employees know about the different forms of payment available under the GPC Pension Plan once they reach retirement age? How do options such as life annuities and lump-sum payments affect the overall financial planning for retiring employees?

Genuine Parts Company employees can choose from various forms of pension payments upon retirement, including life annuities, joint and survivor annuities, and lump-sum payments. Each option affects financial planning differently: life annuities provide steady income, while lump sums offer flexibility but require careful management to ensure long-term financial stability(Genuine Parts Company_P…).

In the event of a termination of employment, what options are available for employees of Genuine Parts Company to access their pension benefits under the GPC Pension Plan? Additionally, what are the specific procedures that employees must follow to ensure they receive their benefits in a timely manner?

In the event of termination, employees who are vested can access their pension benefits, either at their normal retirement age or earlier if they meet the eligibility criteria for early retirement. Employees must submit a request within 180 days of their termination date to receive benefits, with options for lump sum payments for amounts under $75,000(Genuine Parts Company_P…)(Genuine Parts Company_P…).

How can employees of Genuine Parts Company ensure that their beneficiaries are appropriately named under the GPC Pension Plan? What considerations should employees keep in mind when designating beneficiaries, particularly understanding consent needs for spouses and the impact of domestic relations orders?

Genuine Parts Company employees should ensure their beneficiaries are properly named, particularly if married. A spouse is the default beneficiary, but spousal consent is required if an employee designates someone else. Domestic relations orders may also affect beneficiary designations(Genuine Parts Company_P…).

What unique situations might affect the pension benefits of employees at Genuine Parts Company, and how does the plan specifically address employees on military leave or long-term disability? In these circumstances, what communication strategies should employees employ to navigate their benefits?

For employees on military leave or long-term disability, the GPC Pension Plan provides special rules for calculating benefits. These employees should maintain close communication with the Employee Service Center to ensure their benefits are appropriately adjusted(Genuine Parts Company_P…).

Regarding the reporting and update of personal information, why is it essential for employees of Genuine Parts Company to keep the GPC Employee Service Center informed about any changes in marital status or address? How can failure to report these changes potentially impact the pension benefits they receive?

Employees must keep the GPC Employee Service Center informed of any changes in marital status or address, as failure to do so could result in delayed or incorrect pension benefit payments(Genuine Parts Company_P…).

How can employees at Genuine Parts Company reach out for further clarification on the details presented in the Summary Plan Description of the GPC Pension Plan? What resources or contact points are available that could assist in navigating the complexities of the pension plan, ensuring employees can maximize their benefits effectively?

Genuine Parts Company employees can reach out to the GPC Retirement Plan Services through their toll-free number or website for clarification on the pension plan details. These resources are crucial for navigating the complexities of the pension system(Genuine Parts Company_P…).

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

Pension Plan Name of the Pension Plan: Genuine Parts Company Defined Benefit Pension Plan Years of Service and Age Qualification: Employees generally need to have at least 5 years of service to qualify for benefits. Full benefits typically begin at age 65, but early retirement options may be available with reduced benefits. Pension Formula: The pension is calculated based on a formula that takes into account the employee's years of service and average salary over the highest-paid years. 401(k) Plan Name of the 401(k) Plan: Genuine Parts Company 401(k) Plan Eligibility: Employees are eligible to participate in the 401(k) plan after completing 30 days of service. 401(k) Plan Details: The plan allows employees to contribute a portion of their salary to a tax-deferred account, with potential company matching contributions.

Restructuring and Layoffs: In early 2024, Genuine Parts announced a significant restructuring initiative aimed at streamlining operations and enhancing efficiency. This restructuring plan includes the reduction of approximately 5% of its workforce across various divisions. This move is expected to help the company better adapt to market fluctuations and optimize its operational costs. The restructuring reflects broader industry trends as companies adapt to evolving economic pressures and changing market dynamics.

Genuine Parts Company (GPC) Stock Options and RSUs in 2022 GPC offered stock options and RSUs to executives and key employees as part of their compensation package. The stock options typically included a strike price set at market value at the grant date. RSUs granted by GPC generally vested over a period of three to four years, with the exact vesting schedule specified in individual agreements. Genuine Parts Company (GPC) Stock Options and RSUs in 2023 In 2023, GPC continued to offer stock options and RSUs to their management team and senior employees. The stock options were often part of performance-based compensation. The RSUs were allocated with a focus on aligning employee incentives with company performance, typically vesting in tranches over a multi-year period. Genuine Parts Company (GPC) Stock Options and RSUs in 2024 For 2024, GPC maintained its stock option and RSU programs, enhancing the benefits for senior executives and select high-performing employees. The company adjusted the vesting criteria and performance metrics for RSUs to reflect the company's strategic goals and market conditions.

1. Official Website and Key Benefits Information Genuine Parts Company Official Website Visit: Genuine Parts Careers Review sections on employee benefits and health plans. Look for specific healthcare-related terms and acronyms. Key Terms and Acronyms: HDHP: High Deductible Health Plan HSA: Health Savings Account EAP: Employee Assistance Program FSA: Flexible Spending Account PPO: Preferred Provider Organization HMO: Health Maintenance Organization Recent Updates: Genuine Parts Company offers comprehensive health benefits, including medical, dental, and vision plans. They also provide wellness programs and access to telemedicine services. 2. Reliable Sources and Recent Employee Healthcare News a. Glassdoor Search for Genuine Parts Company’s benefits reviews. Look for employee feedback on healthcare coverage and recent changes. b. Indeed Check employee reviews and Q&A sections for insights into health benefits. c. LinkedIn Explore company posts and employee discussions about health benefits. d. BenefitsPro Look for articles or reports on Genuine Parts Company’s health benefits updates and changes. e. Business Insider Search for news articles related to recent changes in health benefits or related employee programs at Genuine Parts. 3. Summary of Findings Healthcare Plans: Genuine Parts offers a range of health insurance options including PPO and HDHP plans, with contributions to HSAs and FSAs. They also provide access to preventive care and wellness programs. Recent Changes: Recent updates to their health benefits have included enhancements to telemedicine services and expanded mental health support through EAP programs. Employee Feedback: Employees generally appreciate the comprehensive coverage but have noted that premium costs and deductibles can be high.