How can fund sponsors and investment advisers transform unregistered products into Investment Company Act of 1940-compliant funds? A conversion under Section 351 of the Internal Revenue Code allows for the transfer of these product lineups — including private funds and separately managed accounts (SMAs) — into a wrapper such as an exchange-traded fund (ETF) without triggering capital gains taxes. Process for Section 351 Conversions Our firm guides fund sponsors and investment advisers through each stage of the Section 351 conversion process — from initial assessment to post-conversion compliance.