The vehicles — Hagerty Holding Corp · Control Empresarial · Silver Lake · 3rd Millennium Trust
Four of the five largest disposals, 9–11 Sep 2026Confirmed · Form 4
Hagerty Holding Corp sold 10,637,500 shares of Hagerty Inc at $11.47 on 9 Sep — $122.0m, the largest disposal of the window. Control Empresarial sold $24.8m of PBF Energy on 9 Sep. Silver Lake partnerships sold roughly $70.3m of Dell on 9 Sep. Stevens sold through 3rd Millennium Trust.
Consensus read
Trusts and holding companies are how the very rich avoid tax. "Buy, borrow, die" — never sell, borrow against the position, let the basis step up at death, pay nothing. The prevalence of entity sellers in the filings is the machinery of avoidance, visible.
Contrarian read
These filings are direct evidence against the story most often told about them. Every transaction listed above is a realisation. Stevens' trust crystallised roughly $646m of gain on near-zero-basis 2006 stock. Hagerty Holding took $122m off the table. Nobody borrowed; everybody sold, and everybody will pay. The structures were not doing tax avoidance this week. Their actual function is control, continuity and centralised timing — which is a less exciting claim and a far more useful one, because it is the part that scales down.
Evidence that discriminates
The 2006 acquisition date combined with the sale. This is the single cleanest test available. If "buy, borrow, die" were operating, a twenty-year-old, essentially zero-basis position is the last asset you would ever sell, because it is the one where the step-up at death is worth most and where borrowing is cheapest relative to the embedded gain. Stevens sold it anyway, at size, in public. That choice is inconsistent with the avoidance model and consistent with a structure whose job is to execute a decision cleanly rather than to defer one forever.
The pattern is entity-as-seller, not entity-as-borrower. Four of the five largest disposals were made by an entity while the individual remained a trustee, officer or partner. What the entity supplied in each case was a single locus for the timing decision and continuity beyond the individual — not leverage.
Scope limit, stated plainly: borrowing against assets is real and is happening at scale elsewhere. My claim is narrower and better evidenced: it is not what happened in these filings, and the popular story is applied far more broadly than the behaviour supports.