Question juridique clé
Whether the waived loans had to be taxed as self-employment income for direct federal tax.
Solution extraite
The loan waivers were taxable income attributable to the Swiss fixed establishment and arose from the taxpayer's self-employed activity.
Motifs extraits
The taxpayer had long treated the loans as business loans; the waivers were linked to her professional model and were not true donations because a counter-performance existed.