The tax treatment of (underpriced) non-family business succession with special consideration of Ticino practice
Does an underpriced transfer of shares to an employee always lead to income tax consequences? With this article, the authors want to stimulate discussion on a very relevant aspect of non-family business succession: the distinction between (income taxable) employee shareholdings and (possibly non-income taxable) succession arrangements. The authors take a look at the practice and case law in the canton of Ticino and other cantons as well as the possible effects of recent inheritance law reforms.
Tax aspects of family business succession
In the coming years, many small and medium-sized companies will face the challenge of arranging their succession. A transfer against payment or free of charge may be considered in order to remain in family ownership. The planning and implementation of succession is an important topic for entrepreneurs with links to numerous areas of law. This article is dedicated to the tax challenges and solution strategies in family business succession in order to support companies in strategically well thought-out and tax-optimized planning.
Taxation of spouses in international relations - tax segregation issues
In the zsis) issue of November 2019, the authors dealt with tax law stumbling blocks in the taxation of spouses in international relationships. In this article, they have focused on the tax segregation of international spouses. On the basis of a test scheme with three questions, they show that a systematic procedure is essential for correct tax segregation and that there is still a need for action here on the part of the assessment authority and the courts.
Far more than cryptocurrencies ...
The editorial for the focus issue "Blockchain, Crypto and NFTs". In recent years, blockchain technology has caused a stir around the world. In this context, tax law has dealt with blockchain technology primarily in connection with cryptocurrencies. However, the scope of blockchain technology goes far beyond cryptocurrencies.
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).
FTA publishes circular no. 50a: Inadmissibility of the tax deduction of bribes
The Federal Tax Administration published the circular "Inadmissibility of the tax deduction of bribes" on December 5, 2023.
Practical questions due to the withholding tax revision from the employee's point of view
Workshop by Patrick Meier and Dirk Hangarter on the occasion of the ISIS) seminar on 31 August 2021 entitled "Withholding Tax Reform: Implications for Practice".
Tax challenges of partnerships
Workshop by Julia von Ah and Toni Hess on the occasion of the ISIS) seminar on 14/15 and 21/22 June 2021 entitled "Corporate Tax Law 2021".
ISIS) seminar "Advance withdrawal, inheritance, division of an estate and execution of a will in tax law" (seminar folder)
Case studies, detailed solutions and slides: Here you will find all the documents (workshops and presentations) according to the following description from the ISIS seminar "Erbvorbezug, Erbgang, Erbteilung und Willensvollstreckung im Steuerrecht" (Advance withdrawal, inheritance, division of an estate and execution of a will in tax law) of 26 November 2020, which was held at the Marriott Hotel in Zurich under the direction of Peter Mäusli-Allenspach.
