With the new loss cap, Kosnitzky said, “You should expect highly sophisticated investment fund and family office managers to also find strategies that arbitrage the tax code to benefit themselves.”

Kosnitzky, who chairs the private client group at Pillsbury Winthrop Shaw Pittman, said he has clients, whom he won’t name, who have bought planes to take advantage of the tax maneuver.

At first glance, buying a multi million-dollar private jet would seem only to compound the potential problem of the business-loss restriction. That’s because “bonus depreciation” creates sizable business losses that are now capped -- potentially making it harder for managers to offset their profits from carried interest.

Yet when they buy a jet, investment-fund and family-office managers are recasting on paper the way they get paid, according to three investment fund professionals. By morphing their carried-interest payouts into management fees that are business income to the fund, managers can soak up the sizable business loss that buying an airplane usually creates.

Managers can thus avoid both what originally would have been a capital gains tax bill on their carried interest, and what would have been ordinary taxes on their management fees.

Jason Traue, a tax partner at Morgan Lewis & Bockius, said funds “are exploring restructuring or structuring new funds to take into account the effect of these rules.”

Business income to a fund, deductible by managers and most outside investors, consists largely of management fees paid by investors, historically 2 percent of assets under management but now 1.45 percent, according to Credit Suisse Group AG.

While the workaround doesn’t affect investors like pension funds or foreign individuals and businesses, it can hurt U.S. individual investors. That’s because the new law ended their ability to deduct their share of the fees -- now increased as a result of the airplane buys.

Before the Republican tax overhaul, businesses of all stripes could generally deduct all of their business expenses. The old rule was meant to encourage companies, especially startups that run losses in early years, to grow over the long term.

Owners of pass-throughs, like hedge fund and other money managers, can now deduct only a small chunk of business losses that exceed their business income -- $250,000 for a single filer, or $500,000 if married filing jointly. Any leftover, or “excess,” losses have to be carried forward to future years and can reduce only 80 percent of taxable income.