Questão jurídica principal
Whether negative currency conversion differences from functional-currency accounting are deductible for direct federal tax.
Decisão extraída
They are not deductible; BGE 136 II 88 applies to all pending assessments and excludes such conversion differences as non-business-related.
Fundamentação extraída
There was no protected reliance or transitional exception. The earlier decision clarified existing law, not a new rule, and the applicable statutory provisions were unchanged.