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	<title>Comments for Bob Pozen</title>
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		<title>Comment on Jumpstarting Hedge Funds by michaelscofield</title>
		<link>http://bobpozen.com/2012/03/jumpstarting-hedge-funds/comment-page-1/#comment-940</link>
		<dc:creator>michaelscofield</dc:creator>
		<pubDate>Tue, 03 Apr 2012 14:32:27 +0000</pubDate>
		<guid isPermaLink="false">http://bobpozen.com/?p=1861#comment-940</guid>
		<description>&quot;If Congress intended the JOBS Act to facilitate capital raising by small businesses, it might want to reconsider the significant advantages the Act confers on hedge funds.&quot;
Agreed. If there isn&#039;t a means by way of JOBS-Act to ensure that the extra capital raised by the hedge funds would mostly, if not wholly, find its way to the small businesses - then perhaps Congress might even want to consider renaming it to the HEDGE Act.

Neil, I&#039;d presume the assumption here is that most sophisticated, read &#039;accredited&#039;, investors would have earned/ built/ maintained a high income/ net worth through a certain savvy. And, IMO prudent principal behaviours beget prudent firm stewardship beget relatively sound performance, would follow in hedge fund industry.</description>
		<content:encoded><![CDATA[<p>&#8220;If Congress intended the JOBS Act to facilitate capital raising by small businesses, it might want to reconsider the significant advantages the Act confers on hedge funds.&#8221;<br />
Agreed. If there isn&#8217;t a means by way of JOBS-Act to ensure that the extra capital raised by the hedge funds would mostly, if not wholly, find its way to the small businesses &#8211; then perhaps Congress might even want to consider renaming it to the HEDGE Act.</p>
<p>Neil, I&#8217;d presume the assumption here is that most sophisticated, read &#8216;accredited&#8217;, investors would have earned/ built/ maintained a high income/ net worth through a certain savvy. And, IMO prudent principal behaviours beget prudent firm stewardship beget relatively sound performance, would follow in hedge fund industry.</p>
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		<title>Comment on Jumpstarting Hedge Funds by neil mcinnis</title>
		<link>http://bobpozen.com/2012/03/jumpstarting-hedge-funds/comment-page-1/#comment-939</link>
		<dc:creator>neil mcinnis</dc:creator>
		<pubDate>Mon, 02 Apr 2012 13:23:58 +0000</pubDate>
		<guid isPermaLink="false">http://bobpozen.com/?p=1861#comment-939</guid>
		<description>Might I suggest that we re-work the 1982 &quot;accredited investor&quot; qualification to a common sense test rather than income and net worh test.  I am not so sure a 200k or even a 600k income is any measure of sophistication.  By the way what does sophistication have to do with prudent investor behavior?</description>
		<content:encoded><![CDATA[<p>Might I suggest that we re-work the 1982 &#8220;accredited investor&#8221; qualification to a common sense test rather than income and net worh test.  I am not so sure a 200k or even a 600k income is any measure of sophistication.  By the way what does sophistication have to do with prudent investor behavior?</p>
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		<title>Comment on The Good and the Bad of Private Equity by Sinem</title>
		<link>http://bobpozen.com/2012/02/the-good-and-the-bad-of-private-equity/comment-page-1/#comment-921</link>
		<dc:creator>Sinem</dc:creator>
		<pubDate>Sat, 10 Mar 2012 17:07:18 +0000</pubDate>
		<guid isPermaLink="false">http://bobpozen.com/?p=1824#comment-921</guid>
		<description>To-the-point article.  Here are cupole thoughts. What excites me is that positive changes are emerging for the US private equity industry comparing to 2009-2010, supported by improved valuations and conditions in the capital markets. The PE industry has not been immune to the affects of the struggling economy, as 2009 results demonstrated, but performance to date in 2011 has been encouraging. Opportunities abound in the current environment given ample PE investors capital to deploy, and evidence that some of the best performing private equity vintage returns, historically, were made near the bottom of the cycle.</description>
		<content:encoded><![CDATA[<p>To-the-point article.  Here are cupole thoughts. What excites me is that positive changes are emerging for the US private equity industry comparing to 2009-2010, supported by improved valuations and conditions in the capital markets. The PE industry has not been immune to the affects of the struggling economy, as 2009 results demonstrated, but performance to date in 2011 has been encouraging. Opportunities abound in the current environment given ample PE investors capital to deploy, and evidence that some of the best performing private equity vintage returns, historically, were made near the bottom of the cycle.</p>
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		<title>Comment on Some Quick Thoughts on the Math of Obama&#8217;s Corporate Tax Reform Plan by M. Phillips</title>
		<link>http://bobpozen.com/2012/02/some-quick-thoughts-on-the-math-of-obamas-corporate-tax-reform-plan/comment-page-1/#comment-918</link>
		<dc:creator>M. Phillips</dc:creator>
		<pubDate>Fri, 24 Feb 2012 22:19:19 +0000</pubDate>
		<guid isPermaLink="false">http://bobpozen.com/?p=1840#comment-918</guid>
		<description>I&#039;d be interested in your opinion on the proposed minimum tax on overseas profits. There are already significant tax incentives for corporations to transfer or develop intangible assets off-shore; with a minimum international tax there would be even more reason to avoid the U.S. entirely if possible. Ideally we&#039;d have a system that encouraged R&amp;D without penalizing non-U.S. aspects of a corporate structure.</description>
		<content:encoded><![CDATA[<p>I&#8217;d be interested in your opinion on the proposed minimum tax on overseas profits. There are already significant tax incentives for corporations to transfer or develop intangible assets off-shore; with a minimum international tax there would be even more reason to avoid the U.S. entirely if possible. Ideally we&#8217;d have a system that encouraged R&amp;D without penalizing non-U.S. aspects of a corporate structure.</p>
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		<title>Comment on The Good and the Bad of Private Equity by Joe Seydl</title>
		<link>http://bobpozen.com/2012/02/the-good-and-the-bad-of-private-equity/comment-page-1/#comment-906</link>
		<dc:creator>Joe Seydl</dc:creator>
		<pubDate>Thu, 09 Feb 2012 22:42:39 +0000</pubDate>
		<guid isPermaLink="false">http://bobpozen.com/?p=1824#comment-906</guid>
		<description>Great summary. I also think that the net effect of PE funds is positive for the economy. As you mention, however, there are trade-offs. CEPR has a piece that&#039;s similar to yours, though a little more in depth: http://www.cepr.net/index.php/blogs/cepr-blog/plain-talk-about-private-equity.

The issue of carried interest is a no brainer. The whole point of the preferential tax treatment of carried interest is to reward those whom risk their own capital. As the CEPR piece notes, it&#039;s very common for PE managers to receive the lower tax rates associated with income from carried interest without risking very much capital at all. It shouldn&#039;t be that hard for the IRS to do the due diligence and end the preferential tax treatment for PE managers that are not risking much capital.

The issue of PE funds loading companies with debt is equally suspect. As you mention, this puts acquired companies at a higher risk of going bankrupt. But another important point is that bankruptcy is often the point, from the perspective of the PE manager, of acquiring a company in the first place. It&#039;s not uncommon for a PE fund to buy a company then force it into bankruptcy in a effort to rid the company of its retirement and pension liabilities. For example, shortly after Sun Capital purchased Friendly&#039;s in 2008, Friendly’s declared bankruptcy and sought to use the bankruptcy proceedings to write off debt and to rid itself of its pension obligations to its 6,000 employees and retirees, thus transferring  responsibility for these pensions to the Pension Benefit Guaranty Corporation (the tax payer). Cases like this are quite common in the PE industry and end up consuming a tremendous amount of resources on the litigation side, as regulators spend time figuring out whether the bankruptcy move was legal or not. So there&#039;s a lot of economic value lost sorting these cases out.</description>
		<content:encoded><![CDATA[<p>Great summary. I also think that the net effect of PE funds is positive for the economy. As you mention, however, there are trade-offs. CEPR has a piece that&#8217;s similar to yours, though a little more in depth: <a href="http://www.cepr.net/index.php/blogs/cepr-blog/plain-talk-about-private-equity" rel="nofollow">http://www.cepr.net/index.php/blogs/cepr-blog/plain-talk-about-private-equity</a>.</p>
<p>The issue of carried interest is a no brainer. The whole point of the preferential tax treatment of carried interest is to reward those whom risk their own capital. As the CEPR piece notes, it&#8217;s very common for PE managers to receive the lower tax rates associated with income from carried interest without risking very much capital at all. It shouldn&#8217;t be that hard for the IRS to do the due diligence and end the preferential tax treatment for PE managers that are not risking much capital.</p>
<p>The issue of PE funds loading companies with debt is equally suspect. As you mention, this puts acquired companies at a higher risk of going bankrupt. But another important point is that bankruptcy is often the point, from the perspective of the PE manager, of acquiring a company in the first place. It&#8217;s not uncommon for a PE fund to buy a company then force it into bankruptcy in a effort to rid the company of its retirement and pension liabilities. For example, shortly after Sun Capital purchased Friendly&#8217;s in 2008, Friendly’s declared bankruptcy and sought to use the bankruptcy proceedings to write off debt and to rid itself of its pension obligations to its 6,000 employees and retirees, thus transferring  responsibility for these pensions to the Pension Benefit Guaranty Corporation (the tax payer). Cases like this are quite common in the PE industry and end up consuming a tremendous amount of resources on the litigation side, as regulators spend time figuring out whether the bankruptcy move was legal or not. So there&#8217;s a lot of economic value lost sorting these cases out.</p>
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		<title>Comment on The NIH Needs a System to Evaluate NCATS, its New Center for Translational Research by Joe Seydl</title>
		<link>http://bobpozen.com/2012/02/the-nih-needs-a-system-to-evaluate-its-new-center-for-translational-research/comment-page-1/#comment-897</link>
		<dc:creator>Joe Seydl</dc:creator>
		<pubDate>Tue, 07 Feb 2012 17:33:42 +0000</pubDate>
		<guid isPermaLink="false">http://bobpozen.com/?p=1819#comment-897</guid>
		<description>Very interesting, objective commentary. Thanks for sharing.</description>
		<content:encoded><![CDATA[<p>Very interesting, objective commentary. Thanks for sharing.</p>
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		<title>Comment on The payroll tax showdown by Joe Seydl</title>
		<link>http://bobpozen.com/2011/12/the-payroll-tax-showdown/comment-page-1/#comment-873</link>
		<dc:creator>Joe Seydl</dc:creator>
		<pubDate>Fri, 23 Dec 2011 16:42:11 +0000</pubDate>
		<guid isPermaLink="false">http://bobpozen.com/?p=1781#comment-873</guid>
		<description>It is pretty ridiculous that we seemingly run into another political impasse every two months. How is a business expected to plan and invest when it doesn&#039;t know what our country&#039;s tax policy will look like two months from now? I like your go-big-or-go-home $5 trillion plan. But let&#039;s remember that the longer-term budget problem is primarily driven by our broken healthcare system. If we paid the same amount per person for health care as people in other wealthy countries pay, then we would face no long-term deficit problem, as the long-term projections would show budget surpluses rather than deficits. What I&#039;m basically saying is that it would be tough to get $5 trillion in deficit reduction over the next decade without slashing things, such as Social Securitiy, which aren&#039;t necessarily contributing to our longer-term deficit problem and which are overwhelmingly popular among the American people.

As you note, though, whatever approach we take must be balanced. Yes, we need more revenue in the form of modestly higher taxes or a broader tax base, but we also need to restructure some of these generous defined benefit pension programs in the federal sector.  A lot of these programs were structured off the assumption that the economy would grow 3 to 4 percent per year forever, when the reality that we need to come to grips with is that the economy will likely remain in this sluggish 1.5 to 2.5 percent growth pace for some time. I know it doesn&#039;t sound like a whole lot in percentage point terms, but it makes a big revenue difference when compounded over many years.

But we&#039;ll see what happens. I hope our leaders can eventually resolve their ideological differences and start making some compromises!</description>
		<content:encoded><![CDATA[<p>It is pretty ridiculous that we seemingly run into another political impasse every two months. How is a business expected to plan and invest when it doesn&#8217;t know what our country&#8217;s tax policy will look like two months from now? I like your go-big-or-go-home $5 trillion plan. But let&#8217;s remember that the longer-term budget problem is primarily driven by our broken healthcare system. If we paid the same amount per person for health care as people in other wealthy countries pay, then we would face no long-term deficit problem, as the long-term projections would show budget surpluses rather than deficits. What I&#8217;m basically saying is that it would be tough to get $5 trillion in deficit reduction over the next decade without slashing things, such as Social Securitiy, which aren&#8217;t necessarily contributing to our longer-term deficit problem and which are overwhelmingly popular among the American people.</p>
<p>As you note, though, whatever approach we take must be balanced. Yes, we need more revenue in the form of modestly higher taxes or a broader tax base, but we also need to restructure some of these generous defined benefit pension programs in the federal sector.  A lot of these programs were structured off the assumption that the economy would grow 3 to 4 percent per year forever, when the reality that we need to come to grips with is that the economy will likely remain in this sluggish 1.5 to 2.5 percent growth pace for some time. I know it doesn&#8217;t sound like a whole lot in percentage point terms, but it makes a big revenue difference when compounded over many years.</p>
<p>But we&#8217;ll see what happens. I hope our leaders can eventually resolve their ideological differences and start making some compromises!</p>
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		<title>Comment on More challenges for the Brussels pact by Lee Kravitz</title>
		<link>http://bobpozen.com/2011/12/more-challenges-for-the-brussels-pact/comment-page-1/#comment-872</link>
		<dc:creator>Lee Kravitz</dc:creator>
		<pubDate>Thu, 22 Dec 2011 17:42:43 +0000</pubDate>
		<guid isPermaLink="false">http://bobpozen.com/?p=1773#comment-872</guid>
		<description>Mr. Pozen

What do you see the eventual outcome of this to be?

Do you feel that the EU will disband completely or will it stratify into different classes? 

I&#039;m also interested in your opinion on how the Eurozone crisis affects the BRIC&#039;s, especially Latin America and Brazil.

Thank You.</description>
		<content:encoded><![CDATA[<p>Mr. Pozen</p>
<p>What do you see the eventual outcome of this to be?</p>
<p>Do you feel that the EU will disband completely or will it stratify into different classes? </p>
<p>I&#8217;m also interested in your opinion on how the Eurozone crisis affects the BRIC&#8217;s, especially Latin America and Brazil.</p>
<p>Thank You.</p>
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