Questão jurídica principal
Whether the foundation qualifies for tax exemption as a public-benefit or charitable entity under cantonal and federal tax law.
Decisão extraída
No. The foundation mainly supported a professional association pursuing self-help and economic interests, not a charitable purpose; partial exemption also failed because no separate funds or accounts were shown for a potentially exempt public task.
Fundamentação extraída
Although the formal requirements on dedicated and irrevocably tied assets were met, the beneficiaries' activities were not exclusively public or charitable. A trade association is generally not tax-exempt, and a foundation financing such an association cannot derive exemption from that support. The lack of segregated accounts and earmarked assets made any partial exemption impossible.