{"id":"W4390293972","doi":"10.59403/1cnvkf4","title":"Services Permanent Establishments and the Canada–United States Income Tax Treaty","year":2012,"lang":"en","type":"article","venue":"International Transfer Pricing Journal","topic":"Taxation and Legal Issues","field":"Business, Management and Accounting","cited_by":0,"is_retracted":false,"has_abstract":true,"ca_institutions":"","funders":"","keywords":"Tax treaty; Treaty; Context (archaeology); Revenue; Agency (philosophy); State income tax; Income tax; Tax revenue; Double taxation; Gross income; Internal revenue; Public economics; Business; Economics; Political science; Public administration; Direct tax; Tax reform; Law; Economy; Accounting; Geography; Service (business); Sociology","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":[0.002331471,0.0004656059,0.0002992572,0.001310183,0.01422735,0.00583214,0.001537416,0.004802992,0.01028938],"category_scores_gemma":[0.005190612,0.0003372456,0.0006674547,0.002484679,0.008161748,0.002378264,0.002833931,0.009757326,0.0006936934],"about_ca_system_candidate":false,"about_ca_system_consensus":false,"about_ca_system_score_codex":0.05636034,"about_ca_system_score_gemma":0.1200089,"about_ca_topic_candidate":true,"about_ca_topic_consensus":true,"about_ca_topic_score_codex":0.9746879,"about_ca_topic_score_gemma":0.9840745,"domain_scores_codex":[0.9944488,0.0003777431,0.00008549886,0.0003019407,0.002699762,0.002086232],"domain_scores_gemma":[0.9977537,0.0004576654,0.0001486071,0.0001125768,0.001098473,0.0004291598],"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":[0.0000132009,0.000009361837,0.0003730184,0.0000143386,0.000003290253,0.00007775686,0.0005574233,0.0002130793,0.00005985536,0.9379967,0.05608338,0.004598576],"study_design_scores_gemma":[0.00003342129,0.00001890687,0.007336805,0.0001607095,0.0000185779,0.000101353,0.001651536,0.0006342697,0.0002675952,0.04703235,0.9426896,0.00005495146],"study_design_candidate":"not_applicable","study_design_consensus":null,"genre_codex":"other","genre_gemma":"empirical","genre_scores_codex":[0.02201216,0.003174177,0.004429456,0.07897829,0.001403056,0.00009403636,0.0008546049,0.0001135161,0.8889407],"genre_scores_gemma":[0.5728103,0.004101537,0.003590573,0.05420179,0.0008621036,0.0001665143,0.0008276664,0.0001149714,0.3633246],"genre_candidate":"empirical","genre_consensus":null,"teacher_disagreement_score":0.05636034,"threshold_uncertainty_score":0.4089248,"prediction_status":"machine_predicted_unvalidated"},"machine_scores":{"provisional":true,"baseline":true,"maturity_gate_passed":false,"score_opus":0.008682884722078317,"score_gpt":0.2190899223546799,"score_spread":0.2104070376326015,"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."}}