{"id":"W106819386","doi":"","title":"Hybrid Foreign Entities, Uncertain Domestic Categories: Treaty Interpretation Beyond Familiar Boundaries","year":2011,"lang":"en","type":"article","venue":"SSRN Electronic Journal","topic":"Taxation and Legal Issues","field":"Business, Management and Accounting","cited_by":0,"is_retracted":false,"has_abstract":true,"ca_institutions":"University of Toronto","funders":"","keywords":"Tax treaty; Treaty; Interpretation (philosophy); Jurisdiction; Tax law; Political science; Corporation; Reading (process); Law and economics; General partnership; Business; Law; Double taxation; Sociology; Linguistics","routes":{"ca_aff":true,"ca_fund":false,"ca_venue":false,"about_ca":true,"invisible_to_affiliation_only":false},"retraction":null,"screen":null,"direct_labels":[],"prediction":{"model_version":"codex-gemma-dda1882f352a","candidate_categories":[],"consensus_categories":[],"category_scores_codex":[0.0006891204,0.0002166809,0.0002102233,0.0002809177,0.0005723241,0.0007484687,0.0002807154,0.00004987294,0.0003896988],"category_scores_gemma":[0.0001503531,0.0001862831,0.000118379,0.0002128897,0.0001618999,0.001797033,0.00004674363,0.000694319,0.0001896638],"about_ca_system_candidate":false,"about_ca_system_consensus":false,"about_ca_system_score_codex":0.0003739306,"about_ca_system_score_gemma":0.0006659544,"about_ca_topic_candidate":false,"about_ca_topic_consensus":false,"about_ca_topic_score_codex":0.004758209,"about_ca_topic_score_gemma":0.002993218,"domain_scores_codex":[0.99797,0.00002340485,0.0003478134,0.0002070145,0.0002362658,0.001215492],"domain_scores_gemma":[0.999251,0.0000218416,0.0003565151,0.0001511324,0.000198012,0.00002149811],"domain_codex":null,"domain_gemma":null,"domain_candidate":null,"domain_consensus":null,"study_design_codex":"theoretical_or_conceptual","study_design_gemma":"theoretical_or_conceptual","study_design_scores_codex":[0.0001443905,0.00005857413,0.002488364,0.00002761639,0.0001088064,0.00001344511,0.0008445348,0.000008871987,0.0000239805,0.9860616,0.000755701,0.0094641],"study_design_scores_gemma":[0.0006788542,0.00009213216,0.0007550131,0.00002716383,0.0001220883,0.0001126847,0.008248691,0.001300582,0.00005122293,0.9026214,0.08568768,0.0003024246],"study_design_candidate":"theoretical_or_conceptual","study_design_consensus":"theoretical_or_conceptual","genre_codex":"empirical","genre_gemma":"empirical","genre_scores_codex":[0.4791023,0.005167906,0.08936592,0.0008251956,0.002633393,0.0007010523,0.000009133362,0.0005421547,0.421653],"genre_scores_gemma":[0.9949376,0.0003098273,0.00009258887,0.0004842705,0.000758427,0.00001142628,0.00003597256,0.00003167346,0.00333822],"genre_candidate":"empirical","genre_consensus":"empirical","teacher_disagreement_score":0.5158353,"threshold_uncertainty_score":0.7596405,"prediction_status":"machine_predicted_unvalidated"},"machine_scores":{"provisional":true,"baseline":true,"maturity_gate_passed":false,"score_opus":0.01219600154528302,"score_gpt":0.2234026379086599,"score_spread":0.2112066363633769,"validation_status":"score_only:v0-immature-baseline","note":"Baseline scores from an immature model (maturity gate not passed). Scores rank; they never assert a category."}}