If you want to discuss “fair”, I’d tend to agree with you. But taxing them while not screwing out all the other business structures that look just like this (s

If you want to discuss “fair”, I’d tend to agree with you. But taxing them while not screwing out all the other business structures that look just like this (see harryh’s example above) is damn near impossible. Which is why the exemption is in there. Figure that out and it might change. Until then, you risk screwing up all sorts of businesses that are not financial let alone hedge funds.