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Mixing Management Fee Waivers with Mayo

In this article, Professor Grewal examines whether the management fee waiver strategy used by private equity firms to convert ordinary income into long-term capital gains actually works.  He argues that those who have condemned the strategy have overstated their case, especially in light of the changes in the tax-administrative law landscape wrought by Mayo v. United States.  He also argues that the Treasury Department should change its rulemaking practices in order to take into account the Supreme Court’s rejection of tax exceptionalism in Mayo.  To read the article, click here and then press the “download this paper” button.