The Resource A and another v Cantonal Taxation Administration and another Cantonal Taxation Administration and another v A and another : A/4175/2013-ICCIFD / ATA/54/2016
A and another v Cantonal Taxation Administration and another Cantonal Taxation Administration and another v A and another : A/4175/2013-ICCIFD / ATA/54/2016
Resource Information
The item A and another v Cantonal Taxation Administration and another Cantonal Taxation Administration and another v A and another : A/4175/2013-ICCIFD / ATA/54/2016 represents a specific, individual, material embodiment of a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation.This item is available to borrow from 1 library branch.
Resource Information
The item A and another v Cantonal Taxation Administration and another Cantonal Taxation Administration and another v A and another : A/4175/2013-ICCIFD / ATA/54/2016 represents a specific, individual, material embodiment of a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation.
This item is available to borrow from 1 library branch.
- Summary
- Judgment by Geneva Court of Appeal, Administrative Chamber (4th Section) 19 January 2016. The taxpayer in this appeal was a dual US- and Swiss-citizen, having lived in Switzerland since 1979. She was a member of a class of beneficiaries of a trust set up by her great-grandfather. Every year, with the exception of 2006, she received approximately 40,000 CHF from a distribution by the trustee. The trust deed itself required the trustees to make distributions twice a year, though they could retain and accumulate any surplus income. The question arose whether the trust was a fixed interest trust or a discretionary trust for Swiss tax purposes. On the basis of the trust deed, the court concluded that it was a discretionary trust; the fact that the taxpayer had regularly received payments of approximately the same amount (with the exception of one year) did not render it a fixed interest trust
- Language
- eng
- Label
- A and another v Cantonal Taxation Administration and another Cantonal Taxation Administration and another v A and another : A/4175/2013-ICCIFD / ATA/54/2016
- Title
- A and another v Cantonal Taxation Administration and another Cantonal Taxation Administration and another v A and another : A/4175/2013-ICCIFD / ATA/54/2016
- Language
- eng
- Summary
- Judgment by Geneva Court of Appeal, Administrative Chamber (4th Section) 19 January 2016. The taxpayer in this appeal was a dual US- and Swiss-citizen, having lived in Switzerland since 1979. She was a member of a class of beneficiaries of a trust set up by her great-grandfather. Every year, with the exception of 2006, she received approximately 40,000 CHF from a distribution by the trustee. The trust deed itself required the trustees to make distributions twice a year, though they could retain and accumulate any surplus income. The question arose whether the trust was a fixed interest trust or a discretionary trust for Swiss tax purposes. On the basis of the trust deed, the court concluded that it was a discretionary trust; the fact that the taxpayer had regularly received payments of approximately the same amount (with the exception of one year) did not render it a fixed interest trust
- Citation source
- In: International tax law reports. - London. - Vol. 20 (2017), part 1 ; p. 1-27
- Geographic coverage
- Europe
- Language note
- English
- http://library.link/vocab/relatedWorkOrContributorName
- Baker, P
- http://library.link/vocab/subjectName
-
- trust
- wealth tax
- trustee
- case law
- Label
- A and another v Cantonal Taxation Administration and another Cantonal Taxation Administration and another v A and another : A/4175/2013-ICCIFD / ATA/54/2016
- Label
- A and another v Cantonal Taxation Administration and another Cantonal Taxation Administration and another v A and another : A/4175/2013-ICCIFD / ATA/54/2016
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<div class="citation" vocab="http://schema.org/"><i class="fa fa-external-link-square fa-fw"></i> Data from <span resource="http://link.library.ibfd.org/portal/A-and-another-v-Cantonal-Taxation-Administration/xlQRGQ-u1_U/" typeof="Book http://bibfra.me/vocab/lite/Item"><span property="name http://bibfra.me/vocab/lite/label"><a href="http://link.library.ibfd.org/portal/A-and-another-v-Cantonal-Taxation-Administration/xlQRGQ-u1_U/">A and another v Cantonal Taxation Administration and another Cantonal Taxation Administration and another v A and another : A/4175/2013-ICCIFD / ATA/54/2016</a></span> - <span property="potentialAction" typeOf="OrganizeAction"><span property="agent" typeof="LibrarySystem http://library.link/vocab/LibrarySystem" resource="http://link.library.ibfd.org/"><span property="name http://bibfra.me/vocab/lite/label"><a property="url" href="http://link.library.ibfd.org/">International Bureau of Fiscal Documentation</a></span></span></span></span></div>
