HOUSE OVERSIGHT 026780 corporations and S corporations. It is likely that further guidance will be issued on this question, as it may be advantageous for certain general partners to convert their existing entities that hold the carried interest to S corporations, and such general partners may have until March 15, 2018 to accomplish such conversion. Managers of hedge funds and other partnerships that do not hold capital assets for more than three years before their sale may consider whether the carried interest incentive allocation should be replaced with an incentive fee structure. Also, the reduced after-tax value of a carried interest partnership allocation may impact the management company's executive compensation arrangements. Although an earlier version of the tax legislation would have repealed the exemption in the Code which provides that a limited partner's income is exempt from self-employment tax, the final version of the Tax Act does not contain such change in law. II. New 21% Corporate Income Tax Rate and Reduction of the Maximum Rates Applicable to Individuals The Tax Act reduces the 35 percent corporate rate to a flat 21 percent corporate rate. There is no special higher rate for personal service corporations (as existed under prior law). The new 21 percent rate is effective for taxable years beginning on or after January 1, 2018. The corporate alternative tax (AMT) has also been repealed. Such corporate tax changes are permanent. In contrast, the highest applicable federal income tax rate for individuals and other non-corporate taxpayers is reduced from 39.6% to 37%. In addition, the 3.8% "add-on" Medicare contributions tax on an individual's net investment income remains in effect. 1. Possible Use of a "C" Corporation as a Tax Shelter Since the new 21% corporate tax rate is now well below the highest rate applicable to high income individuals, some investment managers may conclude that some or all of their management entities