Private Credit Co-Invest / Carry - Tax Efficiencies

For those with co-invest and carry opportunities in private credit - are you able to avoid paying ordinary income tax rates on either piece? Thinking maybe you’re able to fund the co-invest within a company retirement vehicle or some other tactics? Understand carry is really just excess comp so not too concerned there. But particularly on co-invest, it seems like being taxed at ordinary rates with each distribution would kill a lot of the value as compared to just investing in public markets that you won’t need to liquidate for decades. Kills a lot of the attractiveness of the fund leverage on coinvest too - if you realize 10% returns and have 4% rate on leverage, your gain is 6% which then gets cut in half to ~3% post-tax if you’re up around the 50% marginal rate area. Not a lot of juice there.

 

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