The SEC's action
against Apollo is one in a string of recent enforcement actions that have addressed a variety of
fee and expense practices, including legal
fees, monitoring
fee offsets, broken deal expenses, failure to follow allocation policies and allocation methodology.
In the extreme, if deductible household expenditures (e.g., property taxes, charitable giving, the deductible portion of advisory
fees, etc.) continue while there's no income for the year, taxable income could even be negative, which means the partial Roth conversion would be tax - free just absorbing the otherwise - unusable deductions (which are permanently lost if not
offset against negative income in the same tax year!).