Die steuerliche Behandlung von Sanierungsgewinnen vor dem Hintergrund des bestehenden Zielkonflikts zwischen Insolvenz- und Steuerrecht

This thesis examined the tax treatment of restructuring gains in light of the conflict of objectives that exists between insolvency law and tax law. It was shown that even after the decision of the Large Senate of the Federal Fiscal Court dated 28 November 2016, a claim may be made to exempt restructuring gains from taxation based on personal or substantive inequity directly based on sections 163, 227 German Fiscal Code if additional criteria that express a particular hardship in the respective case are added to the requirements previously indicated in the restructuring decree issued by the Federal Ministry of Finance. The fact that lawmakers created a legal basis so swiftly should be welcomed in regard to restructuring, as ought the fact that lawmakers notified the European Commission of their regulatory intent. The examination showed that the arguments in favour of the plans referred to above are so significant that a negative decision by the Commission would be inexplicable in particular in the context of subsidiarity and national sovereignty. Furthermore, it was shown that a priori there is rightly no constitutional conflict of jurisdiction with the municipalities related to the trade tax given that the process of determining the trade tax factor falls solely within the competence of the tax authorities and, based on established case law, the municipalities have no more authority than what is conferred upon them by the state lawmakers. In addition, the examination made the attempt to show companies due to be restructured potential ways to circumvent disadvantageous or even economically destructive consequences of debt waivers that had previously been subject to value added tax. In this context, it was shown that a remission in the area of value added tax cannot be obtained with certainty on substantive grounds of inequity. Furthermore, the study confirmed that the new definition of a gift under section 7 subsection (8) of the Inheritance and Gift Tax Act was not chosen particularly well given that the text is drafted too broadly. A qualification by means of interpretation, in particular in light of the legislative intent, is required in this case

Ultrahigh transverse thermoelectric power factor in flexible Weyl semimetal WTe₂

Topological semimetals are well known for their interesting physical properties, while their mechanical properties have rarely received attention. With the increasing demand for flexible electronics, we explore the great potential of the van der Waals bonded Weyl semimetal WTe2 for flexible thermoelectric applications. We find that WTe2 single crystals have an ultrahigh Nernst power factor of ~3 Wm−1K−2, which outperforms the conventional Seebeck power factors of the state-of-the-art thermoelectric semiconductors by 2–3 orders of magnitude. A unique band structure that hosts compensated electrons and holes with extremely high mobilities is the primary mechanism for this huge Nernst power factor. Moreover, a large Ettingshausen signal of ~5 × 10−5 KA−1m is observed at 23.1 K and 9 T. In this work, the combination of the exceptional Nernst–Ettingshausen performance and excellent mechanical transformative ability of WTe2 would be instructive for flexible micro-/nano-thermoelectric devices. © 2022, The Author(s)

Anisotropic magnetization, critical temperature, and paramagnetic Curie temperature in the highly anisotropic magnetic Heusler compound Rh₂CoSb

The paramagnetic Curie temperature theta(p) is a concept that describes the magnetic ordering temperature in the well-established Curie-Weiss law. Despite the successful explanations of the magnetic behavior, the anisotropy is not usually considered. Although anisotropic theta(p) has been reported for several layered antiferromagnetic or ferrimagnetic materials owing to the orientation-dependent exchange, in ferromagnetic systems, theta(p) was thought to be almost isotropic for decades, and the occasionally reported small difference has remained unexplained. In this paper, we experimentally report the anisotropic magnetization, critical temperature, and paramagnetic Curie temperature in highly anisotropic magnetic Rh2CoSb caused by a large magnetocrystalline anisotropy. The saturation magnetization along the c axis is 25% larger than that along the a axis. The critical temperature and paramagnetic Curie temperature along the c axis are 6 and 15 K higher than those along the a axis, respectively, as deduced from the Arrott plots and inverse susceptibility. A simple modification of the Curie-Weiss law was made to calculate the anisotropic theta(p), which well explains not only Rh2CoSb, but also many other previously reported ferromagnetic materials

Giant Topological Hall Effect in the Noncollinear Phase of Two-Dimensional Antiferromagnetic Topological Insulator MnBi₄Te₇

Magnetic topological insulators provide an important platform for realizing several exotic quantum phenomena, such as the axion insulating state and the quantum anomalous Hall effect, owing to the interplay between topology and magnetism. MnBi4Te7 is a two-dimensional Z(2) antiferromagnetic (AFM) topological insulator with a Ne ' el temperature of similar to 13 K. In AFM materials, the topological Hall effect (THE) is observed owing to the existence of nontrivial spin structures. A material with noncollinearity that develops in the AFM phase rather than at the onset of the AFM order is particularly important. In this study, we observed that such an unanticipated THE starts to develop in a MnBi4Te7 single crystal when the magnetic field is rotated away from the easy axis (c-axis) of the system. Furthermore, the THE resistivity reaches a giant value of similar to 7 mu Omega-cm at 2 K when the angle between the magnetic field and the c-axis is 75 degrees. This value is significantly higher than the values for previously reported systems with noncoplanar structures. The THE can be ascribed to the noncoplanar spin structure resulting from the canted state during the spinflip transition in the ground AFM state of MnBi4Te7. The large THE at a relatively low applied field makes the MnBi4Te7 system a potential candidate for spintronic applications

Improving thermoelectric performance of TiNiSn by mixing MnNiSb in the half-Heusler structure

The thermoelectric properties of n type semiconductor, TiNiSn is optimized by partial substitution with metallic, MnNiSb in the half Heusler structure. Herein, we study the transport properties and intrinsic phase separation in the system. The Ti1-xMnxNiSn1-xSbx alloys were prepared by arc-melting and were annealed at temperatures obtained from differential thermal analysis and differential scanning calorimetry results. The phases were characterized using powder X-ray diffraction patterns, energy dispersive X-ray spectroscopy, and differential scanning calorimetry. After annealing the majority phase was TiNiSn with some Ni rich sites and the minority phases was majorly Ti6Sn5, Sn, and MnSn2. Ni rich sites were caused by Frenkel defects, this led to a metal-like behavior of the semiconducting specimens at low temperature. For x up to 0.05 the samples showed an activated conduction, whereas for x>0.05 they showed metallic character. The figure of merit for x=0.05 was increased by 61% (ZT=0.45) in comparison to the pure TiNiSn.Comment: 7 pages and 5 figures. Submitted to Physical Chemistry Chemical Physics - RSC Publishing on 6th of October, 201

Large linear non-saturating magnetoresistance and high mobility in ferromagnetic MnBi

A large non-saturating magnetoresistance has been observed in several nonmagnetic topological Weyl semi-metals with high mobility of charge carriers at the Fermi energy. However, ferromagnetic systems rarely display a large magnetoresistance because of localized electrons in heavy d bands with a low Fermi velocity. Here, we report a large linear non-saturating magnetoresistance and high mobility in ferromagnetic MnBi. MnBi, unlike conventional ferromagnets, exhibits a large linear non-saturating magnetoresistance of 5000% under a pulsed field of 70 T. The electrons and holes’ mobilities are both 5000 cm2V−1s−1 at 2 K, which are one of the highest for ferromagnetic materials. These phenomena are due to the spin-polarised Bi 6p band’s sharp dispersion with a small effective mass. Our study provides an approach to achieve high mobility in ferromagnetic systems with a high Curie temperature, which is advantageous for topological spintronics. © 2021, The Author(s)

Pesticide use and safety in the nursery and greenhouse

The Oklahoma Cooperative Extension Service periodically issues revisions to its publications. The most current edition is made available. For access to an earlier edition, if available for this title, please contact the Oklahoma State University Library Archives by email at [email protected] or by phone at 405-744-6311

Particle entrapment as a feedback effect

We consider a suspension of polarizable particles under the action of traveling wave dielectrophoresis (DEP) and focus on particle induced effects. In a situation where the particles are driven by the DEP force, but no external forces are exerted on the fluid, the joint motion of the particles can induce a steady fluid flow, which leads to particle entrapment. This feedback effect is proven to be non-negligible even for small volume concentration of particles.Comment: 4 pages, 4 figures, submitte

El uso y la seguridad de pesticida en el vivero y en el invernadero

The Oklahoma Cooperative Extension Service periodically issues revisions to its publications. The most current edition is made available. For access to an earlier edition, if available for this title, please contact the Oklahoma State University Library Archives by email at [email protected] or by phone at 405-744-6311