In most recent decision, the Supreme Tax Court held that there are no special circumstances that would allow for a retroactive determination of a carryover of donations in the year the donation was made if the correct application was not filed. However, without a separate determination, it is no longer possible to utilize the carryover in the following nine tax assessment years.
The Supreme Tax Court has again held that the real estate transfer tax due on a contribution of a shareholding in another company is to be written off as a current operating expense.