Kernrechtsfrage
Whether euro-denominated bank accounts had to be valued at CHF 1.50 or at the Swiss Federal Tax Administration's year-end average exchange rate of CHF 1.5599.
Extrahierter Entscheid
The accounts had to be booked at the official year-end average exchange rate; the taxpayer could not use a lower conversion rate simply because of a general risk of future exchange losses.
Extrahierte Begründung
Accurate balance-sheet valuation requires the actual year-end value. General future exchange-rate risk does not justify lowering the valuation; no specific, imminent loss or corresponding provision was shown.