“The undersigned organizations are writing to provide comments to the Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) on the proposed regulations relating to disguised payments for services between private equity partnerships and partners under Section 707(a)(2)(A) of the Internal Revenue Code. We strongly support the proposed regulations to close the loopholes in the tax code that permit private equity firms to lower their taxes by converting management fees, typically taxed as ordinary income, into capital gains. “