To: Richard Joslin
Cc: Jeffrey Epstein eevaca ion gma .com)
From: Fenn, Patrick
Sent Thur 2/27/2014 4:09:22 PM
Subject: Re: Camp proposal and Sun Capital
It's a ridiculous position, unsupported by any authority. If you read the carried interest discussion
in Joint Committee reports on the Levin and Obama proposal over the last 7 years, they admit
that PE carry is currently capital gain but should be taxed as ordinary income. Revisionist tax
history by Camp.
From: Richard Joslin
Sent: Thursday, February 27, 2014 9:58 AM
To: Fenn, Patrick
Cc: Jeffrey Epstein
Subject: Camp proposal and Sun Capital
Patrick:
• As you eloquently debated publicly a contrary (and in my belief correct) position on this, I note
that Camp (HWM Chair) apparently believes Sun Capital is applicable to Sec 162 and that PE
activity is a developer/dealer. From page 121
• A partnership (e.g., private equity fund) that is in the business of raising capital, investing in
other businesses, developing such businesses, and ultimately selling them, is in the trade or
business of selling businesses. The businesses bought and sold by the partnership are its inventory.
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