{"id":"W360894783","doi":"","title":"欧米諸国における主要租税判例の紹介(第91回)カナダにおける包括的租税回避否認規定の適用--Lipson対Canada事案[2009 SCC 1]","year":2010,"lang":"ja","type":"article","venue":"月刊税務事例","topic":"Military Technology and Strategies","field":"Engineering","cited_by":0,"is_retracted":false,"has_abstract":false,"ca_institutions":"","funders":"","keywords":"History","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":[0.0007598433,0.0002983009,0.0001638594,0.0007956537,0.003063905,0.002575351,0.000427135,0.00110874,0.01918618],"category_scores_gemma":[0.00195672,0.0002211868,0.000233766,0.0008361632,0.00328671,0.001101505,0.0005748253,0.001152488,0.004765789],"about_ca_system_candidate":false,"about_ca_system_consensus":false,"about_ca_system_score_codex":0.004308974,"about_ca_system_score_gemma":0.0062837,"about_ca_topic_candidate":true,"about_ca_topic_consensus":false,"about_ca_topic_score_codex":0.1169699,"about_ca_topic_score_gemma":0.1494263,"domain_scores_codex":[0.9992871,0.00006414555,0.00002842996,0.0001124834,0.0004079468,0.00009982468],"domain_scores_gemma":[0.9988132,0.0002195098,0.0001006847,0.00007526418,0.0006972549,0.00009407844],"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":[0.0002236972,0.0001470208,0.009296191,0.0002979838,0.00003894035,0.001381909,0.01127715,0.0006298978,0.01423239,0.60855,0.115311,0.2386139],"study_design_scores_gemma":[0.00002206675,0.00008977997,0.0181032,0.0001819634,0.00004987924,0.001159209,0.005059398,0.0003511848,0.0170526,0.04364966,0.9142144,0.00006661836],"study_design_candidate":"not_applicable","study_design_consensus":null,"genre_codex":"other","genre_gemma":"other","genre_scores_codex":[0.07421092,0.00465601,0.005817139,0.008033614,0.0009212972,0.0001162817,0.0003402194,0.00008819644,0.9058164],"genre_scores_gemma":[0.5594381,0.005546307,0.009540233,0.002432836,0.0003230905,0.0000754201,0.0005250747,0.00006942196,0.4220495],"genre_candidate":"other","genre_consensus":"other","teacher_disagreement_score":0.8830302,"threshold_uncertainty_score":0.232578,"prediction_status":"machine_predicted_unvalidated"},"machine_scores":{"provisional":true,"baseline":true,"maturity_gate_passed":false,"score_opus":0.005603003923065911,"score_gpt":0.192660512098563,"score_spread":0.1870575081754971,"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."}}