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Why partnerships thrive in private equity

Reported by Ey
Feb 3, 2026· 2 min read
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Key Takeaways
  • • Partnership structures in private equity remain highly tax-efficient despite the US federal corporate income tax rate stabilizing at 21% since 2018, making them the preferred vehicle for fund formation and investor alignment across diverse stakeholder groups.
  • • Retail democratization of private markets has driven surge in alternative investment funds structured as partnerships, enabling individual investors to access private equity, real estate, and alternative investments previously restricted to institutional investors.
  • • Open-ended private equity funds benefit from partnership flexibility to accommodate varying capital inflows, outflows, and liquidity preferences, enabling funds to adapt to market volatility and changing investor needs while pursuing larger and more diverse investment opportunities.
  • • Partnership structures satisfy competing goals of fund managers, institutional investors, family offices, US taxable investors, foreign investors, and high-net-worth individuals through operational flexibility and scalability that increases return potential.
Summary
Partnership structures have emerged as the dominant organizational vehicle in private equity, driven by fundamental advantages in tax efficiency, operational flexibility, and investor alignment. Despite the US federal corporate income tax rate remaining at a historically low 21% since 2018, partnerships continue to outperform alternative structures as the preferred choice for private equity fund formation. This enduring appeal reflects the unique combination of tax advantages and structural benefits partnerships provide, particularly relevant as the industry undergoes significant evolution in fund diversification and liquidity management strategies.

The democratization of private markets has catalyzed a substantial expansion in retail-accessible alternative investment funds structured as partnerships. These vehicles provide individual investors with access to private equity, real estate, and other alternative asset classes historically reserved for institutions and family offices. Partnership structures prove uniquely effective at satisfying the competing objectives of diverse stakeholder groups, including fund managers, institutional investors, family offices, US taxable and foreign investors, and high-net-worth individuals. This structural flexibility enables these funds to pursue larger and more diverse investment opportunities, directly translating to enhanced return potential across investor bases.

Open-ended private equity funds particularly benefit from the operational flexibility inherent in partnership structures. By accommodating regular capital inflows and outflows, partnerships enable funds to adapt to varying investment horizons and liquidity preferences across their investor bases. This adaptive capacity proves especially valuable in volatile market environments, allowing funds to respond dynamically to changing conditions while maintaining resilience. The combination of scalability, tax efficiency, and operational agility positions partnerships as the optimal vehicle for managers seeking to balance institutional capital requirements with retail investor accessibility, a strategic imperative as alternative asset classes continue to penetrate mainstream investment portfolios.

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Sources

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Ey Why partnerships thrive in private equity