Karen C. Burke (San Diego) has posted Back to the Future: Revisiting the ALI's Carried Interest Proposals on SSRN.  Here is the abstract:

Congress is currently considering carried-interest legislation (section 710) that would limit the ability of service partners to convert ordinary compensation income into tax-favored capital gain. While the problem of conversion undoubtedly merits attention, the premise of the proposed legislation deserves closer scrutiny. This article argues that Treasury may already have the requisite authority under existing law to address capital gain conversion and avoidance of other limitations, and that instead of enacting complex new statutory provisions of uncertain scope Congress should consider directing Treasury to promulgate anti-abuse regulations under section 707(a)(2)(A). The article draws on the the American Law Institute's reform proposals concerning the treatment of service partners.