Taxing Private Equity Funds as Corporate Developers

Boston Bar Association, Tax Section
April 9, 2013

Ameek Ashok Ponda along with Steven M. Rosenthal, Tax Policy Center, Urban Institute & Brookings Institution, were panelists at the Boston Bar Association’s brown bag lunch entitled "Taxing Private Equity Funds as Corporate Developers." Mr. Rosenthal presented his thesis, arguing that the IRS and Treasury should issue regulations under section 1221 treating the gains and losses of private equity funds as ordinary, as set forth in his recent article published in Tax Notes, "Taxing Private Equity Funds as Corporate 'Developers'." Mr. Ponda offered his general reactions to and critique of Mr. Rosenthal’s argument. Marianne Kane, Robinson & Cole LLP, moderated the discussion. 

This event was the first of an occasional series of "Town vs. Gown" discussions sponsored by the BBA’s Tax Section.