b'7. Choose Your Corporate StructureClass A and no priority return of capital to Class A, Class B could incur a first-year taxable event for its portion of the ownership interests.Why Use the 2-Class Structure?To preserve distributions for the management class if the manag-er is removed or replaced.To segregate fees from distributions so that earnings on Class B distributions may be taxable at capital gains rates, versus managers fees, which will be taxed at ordinary income rates. This may include self-employment tax, if applicable.Since Class B retains a percentage of the interests, the manager can allocate those interests as it sees fit amongst persons who pro-vide services to the investor entity. 81'