Story perspectives

Treasury Targets Box ETF and Swap Strategies in IRS Ruling

By Drooid · Sep 28, 2026, 11:10 PM UTC · How we work

Summary

Story summary

The U.S. Treasury Department issued a notice and IRS revenue ruling targeting tax-avoidance ETF and hedge-fund strategies.
The notice flagged swaps, currency derivatives, and box-spread ETFs as potentially abusive tax trades.
Alpha Architect’s $15 billion 1-3 Month Box ETF (BOXX) uses options to convert interest income into capital gains.
AQR Capital Management’s Delphi Plus fund employs swaps to generate ordinary losses that offset taxable income.

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Story summary

The U.S. Treasury Department issued a notice and IRS revenue ruling targeting tax-avoidance ETF and hedge-fund strategies.
The notice flagged swaps, currency derivatives, and box-spread ETFs as potentially abusive tax trades.
Alpha Architect’s $15 billion 1-3 Month Box ETF (BOXX) uses options to convert interest income into capital gains.
AQR Capital Management’s Delphi Plus fund employs swaps to generate ordinary losses that offset taxable income.