Eagle Capital Select Equity ETF: A Concentrated U.S. Value Strategy

The Eagle Capital Select Equity ETF is an actively managed, concentrated portfolio built around undervalued, high-quality companies with strong, underappreciated long-term growth potential. The strategy typically holds 20 to 35 high-conviction positions, aiming to outperform the broader U.S. equity market over time while offering the liquidity and potential tax efficiency of an ETF structure.

Eagle Capital Management is an independent investment management firm headquartered in New York, where original research and rigorous valuation discipline drive long-term investment decisions. The firm’s primary strategy, the Eagle Equity portfolio, has been run under the same investment philosophy since its 1988 inception, and the firm reported $35.1 billion in assets under management as of June 30, 2026.

Section 351 of the Internal Revenue Code is a long standing rule: when one or more persons transfer property to a corporation solely in exchange for that corporation’s stock, no gain or loss is recognized on the transfer. It is the same principle founders rely on when they contribute assets to a newly formed company, applied to portfolios of marketable securities. Advisors often describe it as the 1031 exchange of the equity world, though the two provisions are separate and work differently.

In practice, an investor holding appreciated securities contributes those securities in kind to a newly organized entity and receives shares of that entity in return. Because nothing is sold, no capital gain is realized at the moment of the exchange. The investor’s original cost basis and holding period carry over to the new shares, so the deferred gain travels with them and is recognized when the shares are eventually sold. Deferral is the benefit. Elimination is not on offer.

Alignment is the manager’s call. The diversification test is the tax question, and missing it can cause the transfer to be treated as a taxable sale in full. Other conditions matter in practice as well. The exchange cannot be a pre arranged sale in substance, post contribution changes to the portfolio are examined, tax law can change, and the Internal Revenue Service may look past the form of a transaction to its substance. This is why the work is done with counsel and a tax advisor rather than on the strength of a marketing page.