Kernrechtsfrage
Whether the foundation was entitled to tax exemption retroactively from 2012 rather than only from the filing year 2013.
Extrahierter Entscheid
Tax exemption was properly granted only from the filing date; a retroactive exemption was not required.
Extrahierte Begründung
Exemption is granted on application, and it is for the applicant to prove the requirements. A filing-date rule is justified for practicality and to avoid cascading revision requests from donors. Prior treatment in another canton was not determinative.