Mr. Rosenthal will present 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 will offer his general reactions to and critique of Mr. Rosenthal's
argument, and Ms. Kane will moderate the discussion.
This event is the first of an occasional series of "Town vs. Gown"
discussions sponsored by the Tax Section.