NUA and exchange funds
Have a client with a large concentrated employer stock position. A portion of it (overall it is millions of employer stock) is NUA. He really has no interest in ever selling this company for tax reasons but also emotional/bullish belief in the company. I am trying to get buy in from him in the value of diversifying and protecting his legacy. Exchange funds came up in conversation.
He also has other employer stock that is taxable. Since NUA does not get a step up in basis at death I explained if we were going to diversify eventually and you want to capture NUA we may want to consider diversifying from NUA portion of stock first since this will not be treated as favorably for a step up.
Another advisor was on the call and mentioned if we were to contribute the NUA to an exchange fund we get diversification, tax deferral AND in 7 years when the 50-60 diversified stocks distribute from the exchange fund those stocks are then eligible for a step up in estate.
This is such a niche situation and a quick ai search where I asked it to cite sources didn’t corroborate what the other advisor was saying about the step up.
Anyone ever experienced this and know the answer?