"Steve, you aren't making the job of our lobbyists any easier..."

http://dealbook.blogs.nytimes.com/2007/07/13/tax-loopholes-sweeten-a-deal-for-blackstone/

This is part of why I've taken to advising Mrs. Blunt to relax about the so-called "threat" to carried interest posed by the proposed change in tax law. As we speak, these guys (and these, and these) are I'm sure thinking up ways to avoid the hit.

Conceptually (and this is a good time for the disclaimer) you could structure your partnership agreement with tiered equity, in which general partners (& staff) put up some capital and in return receive a share of the carry. It would appear to be capital gains, as financial capital is at risk. For instance, a mild-mannered young associate could put up $1000 (held in escrow? loaned to her by the firm?), and should the firm lose capital, she would lose the stake. But when carried interest is distributed to the firm's partners and staff, the ratio of return for that $1000 could be far in excess of that offered to limited partners. This is just one idea, but it essentially reflects the tax treatment of options (partnership shares would function a bit like Incentive Stock Options in that case).