Unternehmensbewertung nach HFA 2/1983: Ausländische Einkünfte, steuerliches Anrechnungsverfahren, Ausschüttungspolitik

Bei einer Unternehmensbewertung nach IDW müssen grundsätzlich persönliche Einkommensteuern berücksichtigt werden. Nach dem früheren Anrechnungsverfahren (bis 2000) führten ausländische Einkünfte auf Ebene der Kapitalgesellschaft häufig zu steuerfreien Eigenkapitalzugängen. Bei Ausschüttung an den Anteilseigner unterlagen die Dividenden aber der persönlichen Einkommensteuer. Das Arbeitspapier untersucht, wie unter diesen Bedingungen die Besteuerung sachgerecht bei der Bewertung berücksichtigt werden sollte. -- The German Standard for Business Valuation usually requires allowing for personal income taxes in computing a company value. Until 2000 Germany had a Corporation Tax Imputation System. Foreign income often was tax-exempt on a corporate level, but dividends from that income were taxed by personal income tax. The paper analyzes how taxes should be included in business valuation under these special circumstances to produce adequate results.Unternehmensbewertung,Bewertungsstandard,international,ausländische Einkünfte,Besteuerung,Einkommensteuer,Körperschaftsteuer,Anrechnungsverfahren,Dividendenpolitik,objektivierter Wert,IDW,Institut der Wirtschaftsprüfer,Business Valuation,Valuation Standard,HFA 2/1983,IDW,Institut der Wirtschaftspruefer,Germany,International,Foreign Income,Taxation,Personal Income Tax,Corporate Income Tax,Corporation Tax Imputation System,Dividend Policy

Design and construction of a laboratory system for neuromuscular stimulation of the lower extremities during cycling

Functional Neuromuscular Stimulation (FNS) is a method by which paralyzed muscles are stimulated electrically in order to produce a useful movement. The design and testing of a laboratory system for the modulated control of the lower extremities during FNS-induced cycling on an exercising device (Paracycle) is described. The system hardware, which is designed around a standard IBM compatible Personal Computer, features six independent stimulation channels. Waveform characteristics such as pulse frequency, width and amplitude are defined as a function of the crank position of the Paracycle for each channel. An extensive software package allows programmability of the waveform parameters and supports the user in the definition of stimulation sequences. The effective performance of the complete FNS-controller/ Paracycle system has been demonstrated during a controlled case study with two paraplegic subjects

Near-equilibrium measurement of quantum size effects using Kelvin probe force microscopy

In nano-structures such as thin films electron confinement results in the quantization of energy levels in the direction perpendicular to the film. The discretization of the energy levels leads to the oscillatory dependence of many properties on the film thickness due to quantum size effects. Pb on Si(111) is a specially interesting system because a particular relationship between the Pb atomic layer thickness and its Fermi wavelength leads to a periodicity of the oscillation of two atomic layers. Here, we demonstrate how the combination of scanning force microscopy (SFM) and Kelvin probe force microscopy (KPFM) provides a reliable method to monitor the quantum oscillations in the work function of Pb ultra-thin film nano-structures on Si(111). Unlike other techniques, with SFM/KPFM we directly address single Pb islands, determine their height while suppressing the influence of electrostatic forces, and, in addition, simultaneously evaluate their local work function by measurements close to equilibrium, without current-dependent and non-equilibrium effects. Our results evidence even-odd oscillations in the work function as a function of the film thickness that decay linearly with the film thickness, proving that this method provides direct and precise information on the quantum states.Comment: This document is the unedited author's version of a Submitted Work that was subsequently accepted for publication in Nanoscale, copyright Royal Society of Chemistry after peer review. To access the final edited and published work see doi belo

Characterization of phenolic compounds and their contribution to sensory properties of olive oil

Olive oil is not only known for its pungent, bitter, and fruity taste, but also for its health potential, which is often hypothesized to depend on its phenolic compounds. One hundred extra virgin olive oil samples (monocultivaric as well as blends of varieties) were assessed with regard to their sensory properties and phenolic compound composition. Nineteen phenolic compounds have been determined and correlated with sensory data. In all olive oil samples, oleocanthal and oleacein were the most abundant phenolic compounds, with average amounts of 77.9 mg/kg and 41.8 mg/kg, respectively. The highest correlation coefficient between a sensory descriptor and the phenolic compounds was found for the bitter taste sensation and the total phenolic content with r = 0.72 and in particular, for 3,4-DHPEA-EA, with r = 0.57. Intensity plots were assessed for the three main sensory descriptors fruitiness, bitterness, pungency, and for the quality factor harmony, which is associated with the degree of ripeness aroma of olive oil. Positive correlations for the aroma descriptors freshly cut grass, leaves, and nuts, and the phenolic compounds were especially observed for oleoside 11-methylester and vanillic acid. The present study provides a comprehensive database of phenolic compounds in olive oils from six different varieties and seven countries

Nanoboomerang-based inverse metasurfaces - a promising path towards ultrathin photonic devices for transmission operation

Metasurfaces have revolutionized photonics due to their ability to shape phase fronts as requested and to tune beam directionality using nanoscale metallic or dielectric scatterers. Here we reveal inverse metasurfaces showing superior properties compared to their positive counterparts if transmission mode operation is considered. The key advantage of such slot-type metasurfaces is the strong reduction of light in the parallel-polarization state, making the crossed-polarization, being essential for metasurface operation, dominant and highly visible. In the experiment, we show an up to four times improvement in polarization extinction for the individual metasurface element geometry consisting of deep subwavelength nanoboomerangs with feature sizes of the order of 100 nm. As confirmed by simulations, strong plasmonic hybridization yields two spectrally separated plasmonic resonances, ultimately allowing for the desired phase and scattering engineering in transmission. Due to the design flexibility of inverse metasurfaces, a large number of highly integrated ultra-flat photonic elements can be envisioned, examples of which include monolithic lenses for telecommunications and spectroscopy, beam shaper or generator for particle trapping or acceleration or sophisticated polarization control for microscopy

A Trichotomy for Regular Trail Queries

Regular path queries (RPQs) are an essential component of graph query languages. Such queries consider a regular expression r and a directed edge-labeled graph G and search for paths in G for which the sequence of labels is in the language of r. In order to avoid having to consider infinitely many paths, some database engines restrict such paths to be trails, that is, they only consider paths without repeated edges. In this paper we consider the evaluation problem for RPQs under trail semantics, in the case where the expression is fixed. We show that, in this setting, there exists a trichotomy. More precisely, the complexity of RPQ evaluation divides the regular languages into the finite languages, the class Ttract (for which the problem is tractable), and the rest. Interestingly, the tractable class in the trichotomy is larger than for the trichotomy for simple paths, discovered by Bagan, Bonifati, and Groz [JCSS 2020]. In addition to this trichotomy result, we also study characterizations of the tractable class, its expressivity, the recognition problem, closure properties, and show how the decision problem can be extended to the enumeration problem, which is relevant to practice

Different response to eccentric and concentric training in older men and women

Sarcopenia is the age-related loss of muscle mass and strength and has been associated with an increased risk of falling and the development of metabolic diseases. Various training protocols, nutritional and hormonal interventions have been proposed to prevent sarcopenia. This study explores the potential of continuous eccentric exercise to retard age-related loss of muscle mass and function. Elderly men and women (80.6±3.5years) were randomized to one of three training interventions demanding a training effort of two sessions weekly for 12weeks: cognitive training (CT; n=16), conventional resistance training (RET; n=23) and eccentric ergometer training (EET; n=23). Subjects were tested for functional parameters and body composition. Biopsies were collected from M. vastus lateralis before and after the intervention for the assessment of fiber size and composition. Maximal isometric leg extension strength (MEL: +8.4±1.7%) and eccentric muscle coordination (COORD: −43±4%) were significantly improved with EET but not with RET (MEL: +2.3±2.0%; COORD: −13±3%) and CT (MEL: −2.3±2.5%; COORD: −12±5%), respectively. We observed a loss of body fat (−5.0±1.1%) and thigh fat (−6.9±1.5%) in EET subjects only. Relative thigh lean mass increased with EET (+2.5±0.6%) and RET (+2.0±0.3%) and correlated negatively with type IIX/type II muscle fiber ratios. It was concluded that both RET and EET are beneficial for the elderly with regard to muscle functional and structural improvements but differ in their spectrum of effects. A training frequency of only two sessions per week seems to be the lower limit for a training stimulus to reveal measurable benefit