I'm going to be bold, and say where I think the argument on private equity taxation is going to end up.

After all the fuss from the unions and others, it looks like two key areas will be tackled where private equity is vulnerable.

Firstly, I can't see how private equity can defend the 'ratchet' system on a capital gains tax footing. Guy Hands has claimed that money PE execs put in to the companies they own is 'risk capital.' Well, it may be in some cases, But many of them put very small sums in, and see their stakes ratcheted up from 1%, say, to as much as 10%. You can hardly say that the resulting capital gain down the line involved an equivalent amount of 'risk capital.' A review must surely be in order there.

Separately, there is a review under way on whether private equity debt really is debt or equity. There has been discussion for a few years about hybrid capital structures. I'd be surprised if the Revenue didn't feel like striking hard at the use of them and tried to erode some of the advantages not just private equity, but all businesses, can get from them. The issue is not interest relief, as John McFall of the Treasury Select Committee realises, it's the abuse of interest relief.

Both moves would be hard for private equity to object to, and politically I can see those moves satisfying critics. They would be targetted and welcomed I think as intelligent reviews to the tax rules. The last thing Alistair Darling needs to kick off his time as Chancellor is a row along the lines of 'PE tax changes will hammer A.N.Other business sector.'

And a nice irony, if the analysis is right, would be that both reviews appeared to be underway before the whole row kicked off. The taxman wanted to crack down on ratchets last year but couldn't under existing rules. And Ed Balls announced a review earlier this year of debt/equity structures (see paragraph 79 of his March speech).

That's another reason, perhaps, to think civil servants run government, and the rest of us are merely pawns in their game.