Taxpayer v. Cantonal Tax Authority (Legal vs. Beneficial Ownership in Wealth Tax)

A taxpayer challenged a cantonal tax assessment for a specific tax year, arguing that certain assets should not have been included in the calculation of their taxable wealth because they were only legally owned by the taxpayer but beneficially owned by a third party. The court held that for the purposes of wealth taxation, the relevant criterion is legal ownership, not beneficial ownership, as the relevant tax law defines taxable assets based on the holder of the legal right to the property, and thus upheld the tax assessment based on the taxpayer's legal possession of the assets.