Kernrechtsfrage
Whether bonus shares received in 1998 in a migration-induced assessment gap are taxable by special assessment under direct federal tax law.
Extrahierter Entscheid
Yes. Bonus shares count as extraordinary income and remain taxable despite the assessment gap created by the move between cantons using different temporal assessment systems.
Extrahierte Begründung
Art. 47 DBG is not exhaustive in this context. Systematic and teleological interpretation, together with the need to avoid an unjustified tax exemption and unequal taxation, requires covering bonus shares by the special assessment mechanism.