of direct payments for tuition and medical expenses are subject to GST but for this special exclusion. Also, although HEETs have been written about in planning publications, it is unclear how often they are actually implemented: donors who use their GST exemption for multi-generational trusts often feel that they've done “enough” for those lower generations, and may lack the charitable intent necessary for the HEET to work. In addition, given life’s uncertainties, trust creators may be reluctant to limit trust distributions to tuition and medical expenses only. e Tax “carried” (profits) interests as ordinary income. In exchange for their services on behalf of hedge funds and private equity funds, managers of these entities are often compensated with what are called “carried interests,” or profits from the entity. Because these profits interests are structured as partnership interests, they pass through long-term capital gain to the partners/managers, and are therefore taxed at preferential rates. The proposal would not recharacterize the treatment of a partner’s investment in the entity, but would tax as ordinary income what is viewed as compensation for the partner’s investment management services for the partnership. Thus, a partner’s share of income in an “investment services partnership interest” (ISPI), regardless of how the income is characterized at the partnership level, would be taxed as ordinary income, and would also be subject to self-employment tax. An ISPI is an interest in future profits of an “investment partnership”; an investment partnership is one in which substantially all of the entity’s assets are investment-type assets, such as certain securities, real estate, interests in partnerships, commodities, cash or cash equivalents, or derivative contracts related to those assets. e Tighten up conservation easements. Donors of conservation easements typically get a charitable deduction for the permanent restrictions they put on property that will be