Art. 65 Bundesgesetz vom 14. Dezember 1990 über die direkte Bundessteuer (DBG) - Zinsen auf verdecktem Eigenkapital

A/1619/2021 · ge (Art. 65 LIFD)

Company v. Tax Authority (Hidden Equity on Shareholder Loans)

Provision governing the addition of passive interest related to economically assimilated equity to taxable profit, which was part of the dispute resolved by the decision.

604 2018 119 · fr (Art. 65 LIFD)

Shareholder-Guaranteed Mortgage Loans Recharacterized as Hidden Equity and Deductible Interest Limitation

The court's decision to reject the appeal on direct federal tax implicitly confirms the application of Art. 65 LIFD regarding the readjustment of passive interest imputed to the portion of foreign capital assimilated to hidden equity, as reasoned throughout the judgment's legal considerations.

B.2019.87.B.2019.89 · sg (Art. 65 DBG)

Tax Authority Upheld on Profit Adjustments, Loan Reclassification, and Rental Income Disallowance

Cited implicitly in the initial summary as background for the ruling on hidden equity (interest expense deduction context).

B.2019.87.B.2019.89 · sg (Art. 65 DBG)

Shareholder Loans Recharacterized as Hidden Equity and Profit Distribution Upheld

This article, concerning deductible interest on debt that economically constitutes equity for direct federal tax, is cited in the preamble and used in the analysis of disguised equity.

604 2015 105 · fr (Art. 65 LIFD)

Taxpayer Appeal on Hidden Equity Interest Deduction Recalculation

Cited in order 1 as the basis for adjusting the disallowed interest amount on hidden equity for direct federal tax.

80.2013.261 · ti (art. 65 LIFD)

Taxpayer v. Tax Authority: Hidden Equity Classification of Shareholder Loan

Cited in the final order for the appeal being rejected based on the rules regarding hidden equity capital.

SB.2013.00091 · zh (Art. 65 DBG)

Hidden Profit Distribution on Non-Arm's Length Loan

This provision is referenced in the context of tax procedures or obligations.

80.2010.64 · ti (Art. 65 LIFD)

Tax Court Upholds Taxation of Interest on Loan Deemed Hidden Equity Capital

This article provided the legal basis for recognizing interest payments on disguised equity as taxable income, which was the core issue resolved by rejecting the appeal.

A/3003/2007 · ge (art. 65 al. 1 de la loi fédérale sur l’impôt fédéral direct du 14 décembre 1990 (LIFD - RS 642.11))

Tax Revaluation of Asset Acquired via Partnership Liquidation Despite Prior Forced Loss Write-Down

Although cited in the reasoning (para 16) regarding loss carry-forward limits, this provision does not appear in the dispositive orders.

VPB 93-3092 (Art. 65 DBG)

Taxation of Real Estate Cooperatives' Equity

Cited in the motion as the basis for a tax provision that is problematic for housing cooperatives.

80.2013.261 · ti (Art. 65 LIFD)

Swiss Subsidiary Hidden Equity Determination Regarding Related-Party Loan Interest Deduction

This article establishes the legal basis for reclassifying third-party capital economically comparable to equity capital as taxable income for capital companies, which is the core issue leading to the decision.

SB.2014.00024 · zh (Art. 65 Abs. 2 DBG)

State and Municipal Taxes on Private Pension Contributions for International Income

Cited in the final order regarding the deductibility of Pillar 3a contributions for determining the maximum deduction.