A profile of the strategy, the firm behind it, and the people who run it, written for advisors evaluating whether a Section 351 exchange is worth exploring with a client. Nothing here is an offer, a solicitation, or a recommendation of any security or investment product.
The Strategy
The Clough Global Macro strategy is an actively managed strategy that seeks long-term capital appreciation by investing across global asset classes. The manager starts with a top-down view of the macro environment, including monetary policy, growth differentials, geopolitics, and capital flows. It then uses bottom-up fundamental research to choose the instruments that best express each theme. The strategy may invest in equities, interest rates, fixed income, real assets, and derivatives across developed and select emerging markets.
Net equity exposure can range from 0 to 100 percent, and gross exposure may reach 130 percent through ETFs and derivatives. The manager may hedge with options, short positions, and macro overlays, and may hedge currency based on its macro view. Research is organized around four themes. These are long-term structural trends, companies undergoing change, market dislocations, and supply shortages. The fund is not managed relative to a benchmark, although the Bloomberg World Large & Mid Cap TR Index is used for performance comparison.
The fund is expected to launch on or about December 4, 2026, subject to the effectiveness of its registration statement and exchange listing.
Strategy characteristics are targets described by the manager, not limits or guarantees, and may change without notice. Information on this page is provided by the manager and has not been independently verified by ExchangiFi. A registration statement for the fund has been filed with the SEC but is not yet effective. The information is not complete and may change, and shares may not be sold until the registration statement is effective.
Strategy characteristics are targets described by the manager, not limits or guarantees, and may change without notice. Information on this page is provided by the manager and has not been independently verified by ExchangiFi.
See If A Client Portfolio Qualifies
Create a free ExchangiFi account, upload holdings, and run the diversification and liquidity tests before you raise the idea with a client. Free to register, free to use, no credit card.
Clough Capital Partners L.P. is an investment adviser headquartered in Boston. Chuck Clough founded the firm in 2000 after serving as Chief Global Investment Strategist at Merrill Lynch. The firm applies a global macro, research-driven process across its strategies, including three closed-end funds. CMAC offers that process in an ETF structure.
No performance data is presented on this page. Firm diligence materials, Form ADV, and the preliminary prospectus are available directly from the manager. The ETF is distributed by Paralel Distributors LLC. Paralel Distributors LLC and Clough Capital are not affiliated.
A GIPS compliant, independently verified track record refers to the presentation and verification of historical composite performance. It is not a statement about future results, and past performance does not guarantee future results. No performance data is presented on this page. Firm diligence materials, Form ADV and composite performance are available directly from the manager.
The Team
The strategy is managed by Clough Capital's founder and a partner who joined the firm in 2014. Together they bring more than 80 years of combined experience in securities and investment management.
Charles I. Clough, Jr., CFA
Chairman, CIO, Partner & Portfolio Manager
Chuck Clough has worked in the securities and investment business for more than 60 years. He founded Clough Capital in 2000. From 1987 to 1999 he was Chief Global Investment Strategist at Merrill Lynch. He previously held senior roles at Cowen & Co., The Boston Company, Colonial Management Associates, Donaldson, Lufkin & Jenrette, and Alliance Capital Management. He has been a CFA charterholder since 1979. He holds an MBA from the University of Chicago and graduated magna cum laude from Boston College.
Bill Whelan
Partner & Portfolio Manager
Bill Whelan joined Clough Capital in 2014 and has more than 20 years of investment management experience. In 2023 he was named Co-Portfolio Manager of the firm’s three closed-end funds. From 2010 to 2014 he was an Investment Principal at Partners Capital, a private investment office focused on multi-asset investing. Before that he was an equity research analyst at Millennium Management and at Fidelity Management & Research. He holds a B.A. in Economics from Harvard College.
Biographical information is provided by the manager. References to prior firms and roles describe individual professional history only. They are not representations about results achieved at those firms and should not be read as an indication of future performance.
Biographical information is provided by the manager. References to prior firms and roles describe individual professional history only. They are not representations about results achieved at those firms and should not be read as an indication of future performance.
What Is A Section 351 Exchange?
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.
A short walkthrough of the software: uploading holdings, running the diversification and liquidity tests, and reading the results.
What A Contributed Portfolio Has To Clear
80 / 100
Strategy alignment
At least 80 percent of contributed positions should align with the fund's intended portfolio, and 100 percent should sit within the universe of positions the strategy could hold.
25 / 50
Diversification test
Under Section 351(e), no single issuer above 25 percent of contributed value, and the five largest together no more than 50 percent.
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.
More detail, including common questions on qualification, timing and cost, is answered on our Section 351 exchange FAQs.
Outbound link opens the manager's own site. ExchangiFi does not review or endorse third party content.
Register to Access the 351 Exchange Marketplace
Registration is free. Upload a portfolio, run the diversification and liquidity tests, and review manager strategies open to a Section 351 exchange. If you have questions about eligibility, contact us.
Advisors, asset managers, service providers, and counsel comparing notes on eligibility, upcoming launches, regulatory developments, and tax aware strategy.
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Not Financial Advice
This website provides general information only and is not financial, investment, legal, or tax advice.
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