{"id":"W4237532304","doi":"10.32721/ctj.2021.69.1.itp","title":"International Tax Planning: Subsection 15(2) and Partnerships in the Foreign Affiliate Context: Interpretive Arguments in the Absence of Legislative Amendments","year":2021,"lang":"en","type":"article","venue":"Canadian Tax Journal/Revue fiscale canadienne","topic":"Corporate Taxation and Avoidance","field":"Business, Management and Accounting","cited_by":0,"is_retracted":false,"has_abstract":true,"ca_institutions":"","funders":"","keywords":"Context (archaeology); Shareholder; Legislature; Loan; Legislative history; Corporation; Law and economics; Accounting; Interpretation (philosophy); Business; Economics; Law; Political science; Finance; Linguistics; Corporate governance; History","routes":{"ca_aff":false,"ca_fund":false,"ca_venue":true,"about_ca":false,"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":[0.01279872,0.0004956916,0.0005933314,0.001378948,0.009215306,0.01370122,0.002126387,0.007535827,0.003949228],"category_scores_gemma":[0.01459267,0.0005596704,0.0009426195,0.002164738,0.02342558,0.007994898,0.004394769,0.01081387,0.0005617469],"about_ca_system_candidate":false,"about_ca_system_consensus":false,"about_ca_system_score_codex":0.01171377,"about_ca_system_score_gemma":0.0104532,"about_ca_topic_candidate":false,"about_ca_topic_consensus":false,"about_ca_topic_score_codex":0.05520074,"about_ca_topic_score_gemma":0.05153061,"domain_scores_codex":[0.9912392,0.004187463,0.0003538177,0.000962627,0.001620569,0.001636321],"domain_scores_gemma":[0.9948197,0.003265598,0.0005596802,0.0005425134,0.0006171879,0.0001954024],"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":[0.000003202883,0.000002734642,0.0001434274,0.000006929108,0.0000012567,0.00005636719,0.001661463,0.00005355587,0.00001944184,0.9963032,0.001217259,0.0005310994],"study_design_scores_gemma":[0.00003786932,0.00003728598,0.001825711,0.0006082666,0.00005199067,0.0003784157,0.01004828,0.001263607,0.001065057,0.6821505,0.3024657,0.00006713621],"study_design_candidate":"not_applicable","study_design_consensus":null,"genre_codex":"other","genre_gemma":"empirical","genre_scores_codex":[0.03902581,0.003483804,0.0276242,0.03764264,0.0008642488,0.0001281717,0.000144667,0.0001100698,0.8909763],"genre_scores_gemma":[0.9338521,0.00156131,0.007061842,0.01728109,0.0005599181,0.000317983,0.0001051434,0.00009601504,0.03916446],"genre_candidate":"empirical","genre_consensus":null,"teacher_disagreement_score":0.05520074,"threshold_uncertainty_score":0.1097589,"prediction_status":"machine_predicted_unvalidated"},"machine_scores":{"provisional":true,"baseline":true,"maturity_gate_passed":false,"score_opus":0.03888497218747675,"score_gpt":0.2303143264294785,"score_spread":0.1914293542420018,"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."}}