The following is the text of a debate that occurred between Rosenthal and Needham at the May meeting of the American Bar Association Section of Taxation in Washington regarding the proper tax treatment of private equity funds and their partners under current law. The introduction should be attributed solely to Rosenthal. The views expressed by Rosenthal are his own and do not necessarily reflect the views of the Tax Policy Center, the Urban Institute, or the Brookings Institution. The text of the debate has been edited for purposes of clarity and print.