The Prompt Portfolio Paradox

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A growing number of platforms let you type a thesis and an AI builds a custom index. The stock selection might be brilliant. The tax structure is not. A simulation using actual S&P 500 returns (1994 to 2023) shows a $100K investment in a plain S&P 500 ETF grows to $1.54M after taxes. The same money in an AI-generated index reaches $1.24M. That’s $297K surrendered to fees and forced turnover, not bad stock picks. The paradox: the more personalized your portfolio, the less access you have to the structural plumbing that makes investing tax-efficient.

The Ad That Started This

If you listen to podcasts about markets, you’ve heard the pitch. Several platforms now run ads on every finance podcast in your feed: “Type your investment thesis. Our AI builds your portfolio.” Clean energy leaders. AI infrastructure picks. Mars exploration stocks. You describe a conviction, and an AI evaluates thousands of companies, weights them, and hands you a custom index in thirty seconds. One click to buy.

It’s a compelling product. I heard the ad, thought that’s a nice feature, and started digging into how it actually works under the hood. Thirty minutes later I realized it’s not a feature. It’s a bug.

Not the stock selection. The stock selection might be brilliant. The bug is the tax structure wrapping it. A simulation using actual S&P 500 returns from 1994 to 2023 puts a number on the damage: $100K in a Vanguard S&P 500 ETF for 30 years grows to $1.54M after taxes. The same $100K in an AI-generated custom index reaches $1.24M.

The gap: $297,474. Not lost to bad stock picks. Lost to tax plumbing.

The prompt portfolio paradox: the most sophisticated stock selection tool available to retail investors sits inside the least tax-efficient structure. The smarter the personalization, the worse the plumbing. And this disadvantage compounds.

Strange Plumbing

To understand why, you need to know about a piece of financial infrastructure so obscure it makes compiler optimization look mainstream: the in-kind redemption.

When investors sell mutual fund shares, the fund manager sells securities to raise cash. If those securities have appreciated, the fund realizes capital gains and distributes them to all remaining shareholders at year-end. You pay taxes on someone else’s exit. It’s as if every time a neighbor sold their house, you owed taxes on the appreciation of yours.

ETFs fixed this in 1993.1 When institutional players (authorized participants) redeem ETF shares, they exchange them for the underlying securities directly. No sale. No taxable event. No distribution. A structural innovation that costs nothing and requires no skill.

The in-kind redemption tax advantage was never deliberately legislated. It emerged from the interaction of two provisions written decades apart: Section 852(b)(6) of the Internal Revenue Code,10 added by the Tax Reform Act of 1969 to govern how regulated investment companies handle in-kind distributions, and the general non-recognition rules for corporate formations under Section 351.11 When Nate Most designed the ETF creation/redemption mechanism at AMEX in 1992, these provisions together meant ETFs could distribute appreciated securities to authorized participants without recognizing taxable gains. The IRS confirmed this treatment in Revenue Ruling 2001-38.12 Congress has never explicitly blessed the arrangement. It survives because closing it would disrupt trillions in ETF assets.

The plumbing premium: a structural advantage that accrues to any fund that can use in-kind redemptions. Free. Automatic. Invisible. And unavailable to anyone who owns individual stocks.

Personalization Breaks the Wrapper

AI-generated index products are clever.3 You describe an investment thesis in natural language. An AI evaluates thousands of stocks. The platform builds a weighted portfolio of individual stocks you own directly, typically with a low minimum and a 0.40 to 0.50% annual fee.

The personalization works. And personalization is exactly what breaks the tax wrapper.

The result: 0.49% in fees (16x VOO’s 0.03%), no tax-loss harvesting, no in-kind redemption mechanism, and zero structural tax advantages. The stock selection has to outrun a handicap that compounds every year.

Say one of your AI picks doubles. You want to trim the position or exit entirely. That’s a taxable sale at your full rate. In an ETF holding the same stock, an authorized participant redeems shares in kind: the appreciated shares leave the fund, no sale occurs, no capital gains distribute. You notice nothing. The AI gave you a good pick, and the structure ensures you pay full freight on the gains.

The Simulation

I built a simulation to measure the structural cost. Actual S&P 500 index returns from 1994 to 2023. The mutual fund and AI index use real capital gains distribution rates from FXAIX and S&P 500 reconstitution data, respectively. Direct indexing uses a tax-loss harvesting schedule calibrated from academic literature. Four vehicles, each starting with $100,000.

VehicleAnnual CostTax MechanismTurnover
S&P 500 ETF (VOO)0.03% ERIn-kind redemptions, ~0% distributions~4% (index)
Index Mutual Fund (FXAIX)0.015% ERVariable: 0-1.2% (real FXAIX/VFINX data)~4% (index)
AI-Generated Index0.49% feeCG from S&P reconstitution turnover~4% (reconstitution)
Direct Indexing SMA (Schwab)0.40% feeTLH from actual unrealized losses~4% (index)

By year 15, the AI index trails by six figures. By year 30, the gap is catastrophic. The gap accelerates because fees and taxes eat principal that would otherwise grow.

After full liquidation (all vehicles pay 15% LTCG on remaining unrealized gains):

VehicleFinal Valuevs. ETF
S&P 500 ETF$1,541,007Baseline
Index Mutual Fund$1,521,806-$19,201
Direct Indexing$1,421,058-$119,949
AI-Generated Index$1,243,533-$297,474

High fees, forced capital gains, no tax shield.8 Any one alone is survivable. All three at once are devastating. If you wanted to guarantee the worst possible tax outcome from an index, you’d design this. The forces don’t add. They multiply.

Assumptions for reproducibility: actual S&P 500 total returns (1994 to 2023), 15% LTCG / 35% STCG tax rates. MF capital gains distributions from real VFINX data (1994 to 1999) and FXAIX data (2014 to 2019); all other years 0% (loss carryforwards). AI capital gains rates derived from S&P 500 constituent turnover (~4%/yr) multiplied by embedded gain fraction. DI tax-loss harvesting rates calibrated from academic estimates (1 to 2% early, decaying to ~0.2%; spikes in crash years). ETF distributions at 0.05% of NAV. All vehicles fully liquidated at year 30. No additional contributions. Full simulation code on GitHub.

The Direct Indexing Tradeoff

Schwab charges 0.40% annually for direct indexing, 13x the ETF’s fee. It finishes at $1,421,058: $120K below the ETF and $101K below the mutual fund.

The 0.40% management fee eats most of the TLH benefit over 30 years. Tax-loss harvesting still works (those crash-year spikes are real savings), but it can’t overcome the fee drag over three decades. Direct indexing is most valuable if you have large taxable gains elsewhere to offset, high marginal tax rates, and a portfolio above Schwab and Fidelity’s $100K minimums. Without those, a plain ETF wins.

The paradox cuts deeper at the top. Family offices with $50M+ negotiate custom ETF creation baskets with authorized participants, seeding new ETFs with appreciated securities from their existing portfolio without triggering a taxable event.9 When they exit, they redeem in-kind. No sale. No tax. Personalized stock selection with in-kind redemption benefits. The investors who need tax efficiency the least have the most access to it. The plumbing premium scales with wealth. Like most structural features of the financial system.

The Alpha Objection

AI-generated indexes aren’t sold as index replication. They’re sold as alpha. If the AI consistently beats the S&P 500 by 2% annually, the structural drag is worth paying.

AI stock selection is fundamentally different from human fund management. A human analyst covers 30 stocks and relies on intuition shaped by career incentives. An AI evaluates thousands simultaneously, processes earnings calls in seconds, and has no career risk from contrarian positions. The alpha mechanism is different in kind, not degree.

But over the 15 years ending 2023, roughly 90% of large-cap US funds underperformed the S&P 500 after fees.5 Those funds also employed smart people with proprietary data. The 0.49% fee means the AI needs at least 0.46% annual alpha just to match the ETF’s cost structure, before overcoming any tax drag. The tax drag compounds: the AI index needs roughly 0.8% annual alpha to break even with the ETF.

Structure alone costs $297K. If you believe your AI index will overcome that through superior stock selection, you’re betting on AI capability, not fund structure. That bet might pay off. But know the headwind.

When Structure Doesn’t Matter

This analysis applies to taxable brokerage accounts, where roughly 30% of US retail assets sit. In the rest, fund structure is irrelevant:

  • Small portfolios. Below $100K, direct indexing is unavailable and the fee differences compound slowly. ETFs win by default.
  • Short time horizons. Under 5 years, the spread between vehicles is modest. The compounding benefit of tax deferral needs decades to become dramatic.
  • Tax-advantaged accounts (401k, IRA, HSA, Roth). No capital gains tax. No distributions to worry about. No turnover drag. The 0.49% fee is the only cost, and it buys you something a plain index fund cannot: a portfolio built around a specific thesis. Inside a Roth IRA, only fees matter.

What’s More Interesting

The Missing Pieces

AI-generated indexes are the mutual funds of 2026: a good idea trapped inside infrastructure that hasn’t caught up. Mutual funds needed the ETF wrapper to become tax-efficient. AI indexes need their own structural innovation.

The infrastructure is already there. AI index investors own individual stocks. That’s the same foundation direct indexing uses. It could support strategies that none of these platforms currently offer:

  • Tax-loss harvesting. Individual stock ownership already supports it. When Apple drops 8% in a week but the AI’s thesis hasn’t changed, sell for the loss, buy a correlated substitute, keep the thesis intact. Schwab and Wealthfront proved this works at scale. Nobody offers it for AI-generated portfolios.
  • Covered calls. You own the shares. Sell calls on positions where the AI’s conviction is cooling or where implied volatility makes the premium attractive. The income could offset part of the management fee. Harvested losses could offset the short-term tax on premiums. An ETF can’t do this at the position level.
  • Portfolio hedging. Protective puts on concentrated positions. Collars that cap upside in exchange for downside protection. The AI already evaluates the risk profile of every holding. Position-level hedges become possible. Pooled funds can’t offer this.
  • Automated exit strategy. The simulation liquidates everything at year 30, triggering 15% LTCG on all remaining gains. A managed exit unwinds positions over years: specific lot identification, pairing sales with harvested losses, timing exits around low-income years. The liquidation tax bill shrinks from a cliff to a slope.

The Training Problem

This is the interesting AI problem. Not stock selection. The model has to balance tax efficiency, income generation from options, and downside protection simultaneously, shaped by each user’s risk tolerance, income needs, tax bracket, and time horizon. Every trade is a decision with tax consequences, income tradeoffs, and hedging implications. The action space is large, the feedback is delayed (tax outcomes materialize at year-end), and the objective varies per user.

There’s reason to think the training problem is tractable. Tax rules are deterministic: given a sequence of trades, the tax outcome is computable without human labels. Decades of historical stock prices, options chains, and index reconstitution data are public. You could build a simulator and generate millions of portfolio trajectories with known rewards. Offline RL (Decision Transformer,13 Conservative Q-Learning14) has shown promise learning policies from historical trajectories in other domains. Model-based RL15 could plan within such a simulator, testing tax-loss harvesting schedules and covered call strategies across market regimes.

Whether any of this survives contact with real markets is an open question. Simulators miss liquidity constraints, regime shifts, and the feedback loops from crowded trades17. Personalization adds another layer: how much does this user value income over tax savings over downside protection? Tuning that weighting requires RLHF16 data from real users, which means building a platform with enough scale to collect meaningful preferences. You’d start with sensible defaults and hope enough users stick around to generate the preference data for personalization.

The simulation suggests how much room there is. The mutual fund trails the ETF by just $19K over 30 years. Direct indexing trails by $120K with TLH and a 0.40% fee. An AI index with a 0.10% fee, TLH, covered call income, and a managed exit might land in that range: close enough to the ETF that even modest alpha could make the product net-positive. The breakeven would drop from 0.8% annual alpha to something lower, though how much lower depends on execution details nobody’s tested yet. On the regulatory side, Rule 6c-116 standardized custom baskets for ETF creation/redemption, and the SEC has since approved non-transparent active ETFs (Precidian, Fidelity, T. Rowe Price) that disclose holdings quarterly instead of daily. The precedent exists for active strategies inside tax-efficient wrappers, though whether the SEC would allow a non-transparent active ETF with daily trading and in-kind redemptions is an open question.

Conclusion

The current offerings charge 0.49% for what amounts to an API call that picks stocks and hands you the tax bill. The picks could be brilliant. On a risk-adjusted basis, they need to have a 0.8% annual alpha to just to break even with a plain ETF. The interesting product might be not the stock picker, but the agent that manages what happens after the picks. Harvesting losses, generating income from options, hedging concentration, unwinding positions tax-efficiently over decades. Stock selection for a trade was the easy part, executing it and managing the lifecycle is the hard part.

Bibliography


  1. State Street Global Advisors launched the SPDR S&P 500 ETF Trust (SPY) on January 22, 1993. The in-kind creation/redemption mechanism was designed by Nate Most and Steven Bloom at the American Stock Exchange.
  2. 26 U.S.C. § 852(b)(6). Added by the Tax Reform Act of 1969 (Pub. L. 91-172). Provides that a regulated investment company does not recognize gain on distributing property in-kind to shareholders in redemption of its stock, provided the distribution is not in complete liquidation. This provision, originally intended to govern mutual fund in-kind distributions, later became the statutory basis for ETF in-kind redemptions.
  3. 26 U.S.C. § 351. “Transfer to corporation controlled by transferor.” Provides non-recognition treatment when property is transferred to a corporation in exchange for stock, provided the transferors control the corporation immediately after the exchange. In the ETF context, authorized participants transferring securities to create ETF shares qualify under this provision.
  4. IRS Revenue Ruling 2001-38, 2001-2 C.B. 4. Confirmed that an ETF’s transfer of appreciated securities to an authorized participant in exchange for a redemption of ETF shares is treated as a tax-free in-kind redemption under Section 852(b)(6), not as a taxable sale. This ruling effectively blessed the heartbeat trade mechanism that allows ETFs to continuously purge embedded capital gains.
  5. Vanguard. “ETF vs. Mutual Fund Tax Efficiency”. VOO has distributed $0 in capital gains since inception (2010). VFIAX has also distributed $0 in capital gains since VOO was added in 2010, as heartbeat trades purge gains from the entire fund structure. Fidelity’s FXAIX, which has no ETF share class, still distributes small capital gains in some years.
  6. Several platforms now offer AI-generated index products: Public.com’s “Generated Assets,” Composer’s strategy builder, and similar tools from eToro and others. Typical structure: $1,000 minimum, 0.40 to 0.50% annual fee, direct stock ownership in a one-time AI-curated basket.
  7. Schwab. “Personalized Indexing”. Direct indexing with automated tax-loss harvesting, $100K minimum, 0.40% annual fee.
  8. Sialm, C., & Sosner, N. (2018). “Taxes, Shorting, and Active Management.” Financial Analysts Journal, 74(1), 88 to 107. Quantifies the compounding effect of turnover-driven tax drag on long-horizon portfolios.
  9. Chaudhuri, S. E., & Lo, A. W. (2019). “Dynamic Alpha: A Spectral Decomposition of Investment Performance Across Time Horizons.” Management Science, 65(9), 4440 to 4450. Documents how tax-loss harvesting alpha decays as cost basis opportunities are exhausted.
  10. Poterba, J. M., & Shoven, J. B. (2002). “Exchange-Traded Funds: A New Investment Option for Taxable Investors.” American Economic Review, 92(2), 422 to 427. Documents the in-kind creation mechanism and its tax advantages for large investors seeding ETFs with appreciated securities.
  11. S&P Dow Jones Indices. “SPIVA U.S. Scorecard, Year-End 2023”. Approximately 90% of large-cap US equity funds underperformed the S&P 500 over the trailing 15-year period.
  12. Chen, L., Lu, K., Rajeswaran, A., Lee, K., Grover, A., Laskin, M., Abbeel, P., Srinivas, A., & Mordatch, I. (2021). “Decision Transformer: Reinforcement Learning via Sequence Modeling.” Advances in Neural Information Processing Systems, 34. Frames RL as sequence prediction: given a desired return, the transformer generates the action sequence to achieve it. Enables offline RL on historical trajectories without explicit value function estimation.
  13. Kumar, A., Zhou, A., Tucker, G., & Levine, S. (2020). “Conservative Q-Learning for Offline Reinforcement Learning.” Advances in Neural Information Processing Systems, 33. Learns a conservative lower bound on Q-values from a fixed dataset, avoiding the overestimation that plagues standard Q-learning when the agent can’t explore. Designed for exactly the setting where you have historical data but no live environment.
  14. Schrittwieser, J., Antonoglou, I., Hubert, T., Simonyan, K., Sifre, L., Schmitt, S., Guez, A., Lockhart, E., Hassabis, D., Graepel, T., Lillicrap, T., & Silver, D. (2020). “Mastering Atari, Go, Chess and Shogi by Planning with a Learned Model.” Nature, 588, 604 to 609. MuZero learns a dynamics model and plans within it, achieving superhuman performance without access to the true environment rules. The approach generalizes to any domain where you can learn a predictive model of state transitions.
  15. The canonical example: Zillow’s iBuying algorithm. Zillow Offers used ML models to price and automatically purchase homes. But Zillow’s own buying activity inflated prices in the neighborhoods it targeted, which the model interpreted as rising demand, which triggered more aggressive bids. The feedback loop between the model’s actions and the market it was modeling went undetected until Q3 2021, when Zillow disclosed it had accumulated ~7,000 homes it couldn’t sell at predicted prices. The company took a $569M write-down and shut down the program entirely. See Parker, W. & Putzier, K. (2021). “Zillow Quits Home-Flipping Business, Plans to Cut 2,000 Jobs.” The Wall Street Journal, Nov. 2. The same dynamic applies to any algorithmic trading strategy at scale: the model can’t simulate its own market impact.
  16. Christiano, P. F., Leike, J., Brown, T., Marber, M., Legg, S., & Amodei, D. (2017). “Deep Reinforcement Learning from Human Preferences.” Advances in Neural Information Processing Systems, 30. The foundational RLHF paper: trains a reward model from pairwise human comparisons, then optimizes a policy against that learned reward. Enables RL in domains where the objective is subjective or hard to specify programmatically.
  17. SEC. “Rule 6c-11 (2019)”. The “ETF Rule” eliminated the need for individual exemptive orders, standardized custom basket provisions for creation/redemption (enabling heartbeat trades), and paved the way for non-transparent active ETF structures approved through separate exemptive relief (Precidian ActiveShares 2019, Fidelity 2020, T. Rowe Price 2020).