Invalidity of discretionary assessments
With its latest decision of August 19, 2024 (9C_673/2023), published on September 25, 2024, the Federal Supreme Court confirms and clarifies its practice on the nullity of discretionary assessments.
Inheritance and gift tax at federal level - the so-called "Future Initiative" of the JUSO
The "Future Initiative" aims to tax the assets of natural persons through an additional inheritance and gift tax at federal level. With an exemption amount of CHF 50 million, the tax affects wealthy individuals. The proposed tax rate was set at 50%, without providing for exceptions to taxation. Due to the existing inheritance and gift taxes, this could lead to a much higher effective tax burden. Numerous unresolved questions and a planned retroactive effect are already causing great uncertainty well before a referendum at the beginning of 2026. This article uses examples to illustrate possible consequences and measures for action.
Restructuring merger between sister companies
This article first explains the different concepts of the need for reorganization under commercial law and tax law as well as the requirements for the tax recognition of the assumption of loss carryforwards in the context of a reorganization merger between sister companies. The tax consequences for the merged companies and for the joint shareholders are then also examined using examples.
Tax treatment of refurbishment grants in private assets
In the area of capital contributions, two landmark Federal Supreme Court rulings were issued last year. In a first ruling, the Federal Supreme Court also applied an income tax-free repayment within the meaning of Art. 20 para. 3 DBG with regard to hidden capital contributions. In a second ruling last year, the Federal Supreme Court protected the practice of the FTA, according to which the accounting offsetting of a contribution against the loss carryforwards is mandatory in order to claim the restructuring allowance pursuant to Art. 6 para. 1 lit. k StG.
Maximum pillar 3a deductions in tax year 2025
The tax deduction for tied pension provision (pillar 3a) has been adjusted for the 2025 tax year.
Federal Council rejects popular initiative "Yes to fair federal taxes for married couples too"
At its meeting on June 26, 2024, the Federal Council defined its position on the Centre Party's popular initiative "Yes to fair federal taxes for married couples too - finally abolish discrimination against marriage!" and recommends that Parliament reject the initiative without a direct or indirect counter-proposal.
Federal Council rejects popular initiative "For a social climate policy - fairly financed through taxation (Initiative for a future)"
On May 15, 2024, the Federal Council defined its position on the popular initiative "For a social climate policy - fairly financed through taxation (Initiative for a future)".
Federal Council creates national basis for the taxation of teleworking by cross-border commuters
At its meeting on March 1, 2024, the Federal Council adopted the dispatch on the taxation of teleworking in international relations.
Parliament wants more powers for family foundations
On February 27, 2024, the National Council also approved a motion by Aargau FDP Council of States member Thierry Burkart, after the Council of States had already done so. It goes to the Federal Council for implementation.
Federal Council adopts dispatch on individual taxation
At its meeting on February 21, 2024, the Federal Council adopted the dispatch on the popular initiative "For individual taxation regardless of marital status" (tax justice initiative) and the indirect counter-proposal (Federal Act on Individual Taxation).
Inheritance and gift tax procedure
Workshop by Nicole Bühler at the ISIS) seminar on 12 May 2022 entitled "Tax procedural law including appeal procedures".
Tax-free capital gains for natural persons
Workshop by Stefan Oesterhelt and Henk Fenners on the occasion of the ISIS) seminar on 05 April 2022 entitled "Current tax issues in domestic and international M&A transactions".
Seminar folder ISIS)-Seminar "Marriage, Partnership and Family in Tax Law
Case studies, detailed solution notes and slides: Here you will find all the documents of the individual workshops according to the following description from the ISIS) seminar "Marriage, Partnership and Family in Tax Law" of 16 November 2021 under the direction of Peter Mäusli-Allenspach.
