JPMorgan Unit Sues IRS Over Brazilian Fund's Value - McDermott Will & Emery

JPMorgan Unit Sues IRS Over Brazilian Fund’s Value

Overview


M. Todd Welty represents a partnership which held the equity of a Brazilian hedge fund and in which a JPMorgan subsidiary purchased a majority stake. The subsidiary has filed suit against the IRS in US Tax Court, claiming that the agency overestimated the partnership’s taxable value in assessing taxes on the transaction.