With the latest legislation move, The American Jobs and Closing Tax Loopholes Act of 2010″ (H.R. 4213), Archway is already prepared to report fee allocation details providing insight to carried interests breakout.

According to a Hedge Fund Tax Alert (found here) provided by Ernst & Young,  an ISPI is a partnership interest held by a person that provides a substantial quantity of investment management services with respect to specified assets held by the partnership. Specified assets include securities, commodities, real estate held for rental or investment, partnership interests or derivatives with respect to any of the foregoing.  The new provision would apply to hedge, private equity, venture capital, real estate as well as oil and gas funds. There are no carve-outs in the provision for specific industry sectors or fund types. Moreover, these provisions can have broader application to partnerships than one might not consider to be fund arrangements. Also, the provision does not appear to grandfather existing carried interests.