Is the Deduction of Interest on Acquisition Loans Possible? New Developments in LBO Acquisition Structuring in the Netherlands and Switzerland

The publication intends, based on a hypothetical case, to answer the question what the position of the national legislation and tax authorities is with regard to the deductibility of interest payments in an LBO acquisition. Therefore, possible scenarios about the structuring process in two different countries and its treatment by the tax authorities will be made visible and compared with the position of academics. By considering the legislative changes of 2012 in the Netherlands with regard to the deductibility of interest on acquisition loans and the cantonal differences in Switzerland recent developments will be shown and an outlook will be presented. This comparative analysis fosters in addition the understanding of and the meaning by the authorities of national anti-avoidance rules and the term "tax avoidance".

Genetic variation in resistance of Brachypodium distachyon to Rhizoctonia solani AG 8

Wheat is one of the three major cereal crops, alongside rice and maize, which together supply half of the world population's food energy requirement. Wheat production is affected by climatic conditions and biotic factors including weed competition and pathogen attack. Around 18% of yield loss in Australian wheat is attributable to root diseases. Plant defence against root-invading pathogens often involves multiple quantitative resistance genes. Rhizoctonia root rot, caused by 'Rhizoctonia solani' AG 8 (teleomorph 'Thanatephorus cucumeris'), costs Australian farmers around $60 million per annum. The necrotrophic fungus attacks seedling roots, resulting in patches of severely stunted plants. During root invasion R. solani AG 8 secretes a range of enzymes; however specific requirements for pathogenesis are not yet understood. Effective resistance to Rhizoctonia is not available in wheat cultivars, so farmers must rely on management techniques to control the disease. This research aimed to discover genetic resistance to Rhizoctonia root rot in 'Brachypodium distachyon', a grass developed in recent years as a model for cereals. The species has shown strong potential as a model for wheat shoot and crown diseases, as well as cereal root architecture. Two 'B. distachyon' germplasm resources were used in this project: natural accessions collected from Turkey and Spain, and a T DNA insertional mutant collection. 'Rhizoctonia solani' AG 8 produced similar disease phenotypes and severity in 'Brachypodium distachyon' and wheat. A method developed to screen for disease resistance in the 'B. distachyon' collections incorporated toothpick baits to check for the presence of inoculum and contamination in pots. The major indicator of disease severity was reduced root length, with leaf lengths and plant development rate being secondary symptoms. Resistance of different lines was ranked based on the ability of plants grown in infested soil to maintain root and shoot measurements similar to uninfested control plants. Twenty-six genetically diverse natural accessions and 25 selected T-DNA lines of 'B. distachyon' were included in replicated experiments to screen for variation in resistance to 'R. solani' AG 8. Greatest variation in resistance to was identified in the natural accession collection. Root length of the least resistant line was reduced to 19% of the control in 'R. solani' infested soil, while the most resistant line maintained 53% of control root length. This difference is similar to quantitative resistance levels in other grasses and wheat mutant lines described in the literature. Exploring potential resistance mechanisms, nodal root emergence in response to infection correlated with greater resistance in an experiment with natural accessions. Increased endogenous seedling vigour was linked with lower resistance, but this factor alone did not explain all variation in resistance. Further work is required to validate increased resistance associated with a T-DNA tagged gene, Bradi3g14370, that encodes a putative beta-1,3-galactosyltransferase. 'Brachypodium distachyon' was found to be a useful model pathosystem for wheat root diseases. The variation in genetic resistance to 'R. solani' AG 8 described in the natural accession collection provides a basis for further work to discover genes involved in resistance to this pathogen in 'B. distachyon' and subsequently in wheat

Microscopic Theory of Photon-Correlation Spectroscopy in Strong-Coupling Semiconductors

While many quantum-optical phenomena are already well established in the atomic systems, like the photon antibunching, squeezing, Bose-Einstein condensation, teleportation, the quantum-optical investigations in semiconductors are still at their beginning. The fascinating results observed in the atomic systems inspire physicists to demonstrate similar quantum-optical effects also in the semiconductor systems. In contrast to quantum optics with dilute atomic gases, the semiconductors exhibit a complicated many-body problem which is dominated by the Coulomb interaction between the electrons and holes and by coupling with the semiconductor environment. This makes the experimental observation of similar quantum-optical effects in semiconductors demanding. However, there are already experiments which have verified nonclassical effects in semiconductors. In particular, experiments have demonstrated that semiconductor quantum dots (QDs) can exhibit the single-photon emission and generation of polarization-entangled photon pairs. In fact, both atom and QD systems, embedded within a microcavity, have become versatile platforms where one can perform systematic quantum-optics investigations as well as development work toward quantum-information applications. Another interesting field is the strong-coupling regime in which the light-matter coupling exceeds both the decoherence rate of the atom or QD and the cavity resulting in a reversible dynamics between light and matter excitations. In the strong-coupling regime, the Jaynes-Cummings ladder is predicted and shows a photon-number dependent splitting of the new dressed strong-coupling states which are the polariton states of the coupled light-matter system. Although the semiclassical effect of the vacuum Rabi splitting has already been observed in QDs, the verification of the quantum-mechanical Jaynes-Cummings splitting is still missing mainly due to the dephasing. Clearly, the observation of the Jaynes-Cummings ladder in QDs would be a great contribution in the growing field of quantum optics in semiconductors. The efforts in QD systems are again driven by the atomic systems which not only have shown the vacuum Rabi splitting, but also the second rung, e.g. via direct spectroscopy and via photon-correlation measurements. In this thesis, it is shown that spectrally resolved photon-statistics measurements of the resonance fluorescence from realistic semiconductor quantum-dot systems allow for high contrast identification of the two-photon strong-coupling states. Using a microscopic theory, the second-rung resonance of Jaynes-Cummings ladder is analyzed and optimum excitation conditions are determined. The computed photon-statistics spectrum displays gigantic, experimentally robust resonances at the energetic positions of the second-rung emission. The resonance fluorescence equations are derived and solved for strong-coupling semiconductor quantum-dot systems using a fully quantized multimode theory and a cluster-expansion approach. A reduced model is developed to explain the origin of auto- and cross-correlation resonances in the two-photon emission spectrum of the fluorescent light. These resonances are traced back to the two-photon strong-coupling states of Jaynes-Cummings ladder. The accuracy of the reduced model is verified via numerical solution of the resonance fluorescence equations. The analysis reveals the direct relation between the squeezed-light emission and the strong-coupling states in optically excited semiconductor systems

Twitter rhetoric ? Argumentation in a Twitter debate : a case study

International audienceOn the 20th June 2008, “#pdfdebate”, the first presidential campaign debate to be held on Twitter, was launched. For five days, a representative of each of the two major candidates to the US presidential election used their Twitter account to engage in a debate on technology and government, moderated by a famous political blogger. This initiative of Personal Democracy Media, a private foundation dedicated to the study of new technologies in politics, has had no real posterity to this day and was generally considered as a failure. Commentators, both in the press and on Twitter, mostly blamed this failure on the fact that Twitter and its interface are not really suitable for an extended conversation such as a debate. The moderator herself says after a few tweets that “multithread format is making [her] head hurt”. However, it was deliberately conceived as a “freewheeling” experiment, meant to try and see what debating on Twitter would be like. This tentative political debate may then prove to be a good starting point to see what a political debate on Twitter can be like. With discourse analysis and computer-mediated discourse analysis (such as initiated by American linguist Susan Herring) as a frame, it also enables to take a closer look at rhetoric (in its original meaning of “art of public speaking”) on Twitter. Looking at how language is used by the debaters and technics of argumentation used within the notoriously limiting format of the tweet (140 characters), the question is ultimately whether there is such a thing as “Twitter rhetoric”. Since this debate is now seven years old and Twitter has changed quite a bit, the study will also include more recent features added over the years

Kleine Schritte ganz gross - Valide Verlaufsassessments für Kinder mit schweren, erworbenen Hirnverletzungen (Wachkoma) : Ein systematisches Review

Darstellung des Themas: Assessments, als Instrumente zur Verlaufsbeobachtung, spielen eine zentrale Rolle in der Behandlung von Patienten mit schweren, erworbenen Hirnverletzungen und daraus resultierendem Wachkoma. Im Gegensatz zu Assessments für Erwachsene müssen Assessments für Kinder den Entwicklungsstand und dementsprechend noch nicht ausgebildete Fähigkeiten miteinbeziehen. Ziel: Ziel ist, eine allgemeine Empfehlung für die Praxis zur Anwendung valider Verlaufsassessments bei Kindern mit schweren, erworbenen Hirnverletzungen. Die ergotherapeutische Anwendung davon wird diskutiert. Methode: Durch eine systematische Literaturrecherche nach Guba (2007) wurden validierte, internationale und interprofessionelle Assessments eingeschlossen, die zur Verlaufsbeobachtung von Kinder mit schweren, erworbenen Hirnverletzungen im Wachkoma oder Minimally Conscious State verwendet werden können. Die Validierungsstudien wurden nach Validität, Reliabilität und Inhalt des Assessments kritisch beurteilt. Relevante Ergebnisse: 10 von 26 gefundenen Assessments entsprachen den Einschlusskriterien. Es wurden fünf Assessments zur Erfassung des Bewusstseinzustandes und fünf Assessments zur Erfassung der Funktion gefunden. Schlussfolgerung: Eine Mehrheit der gefundenen Assessments kann minimale Veränderungen des Bewusstseinszustands nur ungenügend differenzieren. Das PALOC-s (Eilander et al., 2009) ist geeignet zur Verlaufsbeobachtung des Bewusstseinszustandes, das PCANS (Soo, Tate, Williams, Waddingham & Waugh, 2008) wird empfohlen zur Verlaufsbeobachtung der Funktion. Für die ergotherapeutisch relevante Erfassung bedeutungsvoller Aktivitäten werden zusätzliche Assessments empfohlen

Triassic palynology of the Swiss Belchentunnel: a restudy of the Scheuring samples

Well-preserved Carnian (Late Triassic) palynomorphs are rare in Switzerland, despite sediments include one of the important plant fossil localities, Neue Welt near Basel. Modern detailed palynological studies on Triassic palynomorphs in general and especially in the Carnian are scarce, most palynological studies were carried out more than 50 years ago. Nevertheless (Late) Triassic sediments still yield surprises for palynological research. Here, we present the results of the re-study of the famous Belchentunnel samples that were studied and published by Bernhard Scheuring in 1970. The less cheerful result concerns the preservation of slides: more than 60% of the slides are degraded. On the other hand, the restudy of the well-preserved slides showed an unexpected number of algae, acritarchs, and spore taxa not described so far. Especially the spores facilitate the correlation with the well-known biostratigraphic schemes established for the Germanic Basin. The distribution of Porcellispora longdonensis throughout the Belchentunnel succession is especially striking. The acme just below the Schilfsandstein might suggest the presence of ephemeral ponds

A general treatment of snow microstructure exemplified by an improved relation for thermal conductivity

Finding relevant microstructural parameters beyond density is a longstanding problem which hinders the formulation of accurate parameterizations of physical properties of snow. Towards a remedy, we address the effective thermal conductivity tensor of snow via anisotropic, second-order bounds. The bound provides an explicit expression for the thermal conductivity and predicts the relevance of a microstructural anisotropy parameter <i>Q</i>, which is given by an integral over the two-point correlation function and unambiguously defined for arbitrary snow structures. For validation we compiled a comprehensive data set of 167 snow samples. The set comprises individual samples of various snow types and entire time series of metamorphism experiments under isothermal and temperature gradient conditions. All samples were digitally reconstructed by micro-computed tomography to perform microstructure-based simulations of heat transport. The incorporation of anisotropy via <i>Q</i> considerably reduces the root mean square error over the usual density-based parameterization. The systematic quantification of anisotropy via the two-point correlation function suggests a generalizable route to incorporate microstructure into snowpack models. We indicate the inter-relation of the conductivity to other properties and outline a potential impact of <i>Q</i> on dielectric constant, permeability and adsorption rate of diffusing species in the pore space

Brachypodium distachyonis a pathosystem model for the study of the wheat disease rhizoctonia root rot

Brachypodium distachyon (Bd) is increasingly being used as a model for cereal diseases and to study cereal root architecture. Rhizoctonia solani AG 8 is a necrotrophic root pathogen that infects wheat soon after germination resulting in reduced plant growth and yield loss. Genetic resistance to R. solani AG 8 is not available in commercial wheat cultivars, although some quantitative levels of resistance have previously been found in mutant lines and grass relatives. Resistance mechanisms in cereals remain unknown. The ability to use Bd as a model to study the wheat–R. solani AG 8 pathosystem was investigated. The results presented show that Bd is susceptible to R. solani AG 8 and that the pathogen infects both species to a similar degree, producing comparable disease symptoms. Root length reduction was the primary indicator of disease, with shoots also affected. The second objective was to develop a repeatable phenotyping method to screen Bd populations for resistance to R. solani AG 8. Results of a preliminary experiment provide evidence for variation in resistance between Bd inbred lines. This is the first report showing the potential of Bd as a model plant for discovery of quantitative genetic variation in resistance to a necrotrophic cereal root pathogen.This work was carried out for K. S.'s PhD thesis and funded by the Australian Grains Research and Development Corporation