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Fidelity International Currency Advisor A Fund, LLC, By the Tax Matters Partner v. United States of America

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Before Torruella, Boudin and Thompson, Circuit Judges.

Fidelity International Currency Advisor A Fund (“Fidelity”) seeks review of a district court judgment resolving a controversy between Fidelity and the Internal Revenue Service (“IRS”). In substance, the district court sustained IRS adjustments to Fidelity’s partnership returns for the two tax years at issue and upheld a 40 percent penalty for tax underpayment. Fid. Int’l Currency Advisor A Fund, LLC v. United States, 747 F. Supp. 2d 49 (D. Mass. 2010).

The litigation arises out of the following events. Richard Egan was the founder of EMC Corporation, a manufacturer of computer storage devices, and in the early years of this ultimately successful business, Egan received non-qualified options to acquire EMC stock. When he exercised those options in 2001, they generated $162 million of ordinary income for him and his wife; it was estimated this could create a tax liability of over $63 million.

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