Ok they are affiliated entities, but the it seems relevant to me <i>how</i> they are affiliated. Since the manager is owned by the fund, it seems there is an argument that the entirety of the manager&#x27;s business is an expense to the fund, just like if a company buys its own airplane and hires its own pilots and ground crew, instead of flying commercial all the time. Or like how Apple bought a bunch of semiconductor companies to design chips in-house, instead of just buying off-the-shelf components.<p>Reducing costs is typically one of the main reasons one organization buys or incorporates a subsidiary, instead of just going into the marketplace for what they need. Will that now be illegal if it reduces the total tax payments of the formerly separate organizations, as a side effect? That seems like a pretty dramatic intrusion into business decision-making.