In other words, the longer than 1-year holding period, the return of 100% of the initial capital to the limited partners, and the full and equal risk that managers take alongside their limited partners (plus it is common for the managers to put some of their own money into the fund) all justify carried interest treatment as a capital gain.
If Leeds can stay up this season Hetherington has negotiated with Premier Rugby Limited to be given an equal share of the money the umbrella organisation shares out to its top-flight clubs.