{"id":"W216271840","doi":"","title":"欧米諸国における主要租税判例の紹介(第82回)カナダにおける包括的租税回避否認規定と同規定創設後における租税回避事例--Canada Trustco対Canada事案[2005 SCC 54]","year":2009,"lang":"ja","type":"article","venue":"月刊税務事例","topic":"Diverse Scientific and Economic Studies","field":"Economics, Econometrics and Finance","cited_by":0,"is_retracted":false,"has_abstract":false,"ca_institutions":"","funders":"","keywords":"Geography","routes":{"ca_aff":false,"ca_fund":false,"ca_venue":false,"about_ca":true,"invisible_to_affiliation_only":true},"retraction":null,"screen":null,"direct_labels":[],"prediction":{"model_version":"metacan-v3-hybrid-931329e0061c","candidate_categories":[],"consensus_categories":[],"category_scores_codex":[0.001722006,0.0003587288,0.0003122697,0.001428765,0.005021017,0.003421769,0.0006821982,0.001689002,0.01266905],"category_scores_gemma":[0.004494981,0.0003521336,0.0004208855,0.001680827,0.009562722,0.002636958,0.0008441512,0.002507104,0.002678214],"about_ca_system_candidate":false,"about_ca_system_consensus":false,"about_ca_system_score_codex":0.009380978,"about_ca_system_score_gemma":0.01221719,"about_ca_topic_candidate":true,"about_ca_topic_consensus":false,"about_ca_topic_score_codex":0.3601183,"about_ca_topic_score_gemma":0.3807965,"domain_scores_codex":[0.9987546,0.0001350019,0.00005918592,0.0002056284,0.0006509617,0.0001947085],"domain_scores_gemma":[0.9973674,0.0005818646,0.0001843225,0.0001637589,0.001556067,0.0001465606],"domain_codex":null,"domain_gemma":null,"domain_candidate":null,"domain_consensus":null,"study_design_codex":"theoretical_or_conceptual","study_design_gemma":"not_applicable","study_design_scores_codex":[0.00005892611,0.00004512941,0.004768318,0.0001310136,0.00003007987,0.0006208925,0.007508893,0.0004011183,0.001169975,0.8656831,0.060283,0.05929951],"study_design_scores_gemma":[0.00002456703,0.00003354176,0.03130061,0.0003074194,0.00008434329,0.000925239,0.006004645,0.000647226,0.005302745,0.3448318,0.6104314,0.0001064135],"study_design_candidate":"not_applicable","study_design_consensus":null,"genre_codex":"other","genre_gemma":"empirical","genre_scores_codex":[0.05151103,0.009751158,0.01375177,0.02392542,0.0009518412,0.0001187977,0.0006186833,0.0001027044,0.8992686],"genre_scores_gemma":[0.6541893,0.007351376,0.01767998,0.007317644,0.0005104428,0.0000915521,0.0005560523,0.0001062398,0.3121974],"genre_candidate":"empirical","genre_consensus":null,"teacher_disagreement_score":0.6398817,"threshold_uncertainty_score":0.7160444,"prediction_status":"machine_predicted_unvalidated"},"machine_scores":{"provisional":true,"baseline":true,"maturity_gate_passed":false,"score_opus":0.02151858546990882,"score_gpt":0.1756448099655449,"score_spread":0.1541262244956361,"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."}}