Fidelity Int'l v. United States – District Court Decision
{"Image DocumentName": "Fidelity Int\u2019l v. United States \u2013 District Court Decision", "Image ImageDescription": "Overview of Court Analysis: From a subjective standpoint, the transactions had no business purpose of any kind. The taxpayers did not enter into the transactions for profit or to provide a hedge or other protection against economic risk, but to shelter capital gains and ordinary income from taxation. The transactions also had no economic substance from an objective standpoint. Relevant Findings for Particular Transactions: Fidelity High Tech. The transaction served no reasonable hedging function. Option trades were not a rational economic hedge. Various components of the transaction served no hedging function. There was no reasonable possibility of profit. Transaction costs and fees were extremely high. Expected return on the transaction was negative. Net present value of the options was negative. One-option payout was not a real possibility. Options were not profitable. Fidelity International. Interest rate and currency option transactions were not rational economic hedges. Capital structure was not rational. Costs and fees for the transaction were extremely high. Expected rate of return for the transaction was negative. Transaction was intended to be profitless.", "Image XResolution": "37", "Image YResolution": "37", "Image ResolutionUnit": "Pixels/Centimeter", "Image Software": "SlidePlayer", "Image YCbCrPositioning": "Centered"}