{"id":"W4410236107","doi":"10.32721/ctj.2025.73.1.itp","title":"International Tax Planning: The Fallout from Alta Energy Luxembourg—The Application of GAAR to Tax Treaties","year":2025,"lang":"en","type":"article","venue":"Canadian Tax Journal/Revue fiscale canadienne","topic":"Taxation and Legal Issues","field":"Business, Management and Accounting","cited_by":1,"is_retracted":false,"has_abstract":true,"ca_institutions":"","funders":"","keywords":"Tax planning; International trade; Business; International economics; Political science; Double taxation; Economics; Law; Tax avoidance","routes":{"ca_aff":false,"ca_fund":false,"ca_venue":true,"about_ca":true,"invisible_to_affiliation_only":true},"retraction":null,"screen":null,"direct_labels":[],"prediction":{"model_version":"codex-gemma-dda1882f352a","candidate_categories":[],"consensus_categories":[],"category_scores_codex":[0.0003445452,0.0002136641,0.0002538732,0.0006314336,0.0005428107,0.000431937,0.001016102,0.0001027423,0.00054045],"category_scores_gemma":[0.0003601357,0.0001611664,0.0001220561,0.0006726519,0.00009425323,0.0003624504,0.00007440623,0.0002985255,0.00004180913],"about_ca_system_candidate":false,"about_ca_system_consensus":false,"about_ca_system_score_codex":0.0003584496,"about_ca_system_score_gemma":0.0002044745,"about_ca_topic_candidate":true,"about_ca_topic_consensus":true,"about_ca_topic_score_codex":0.7631242,"about_ca_topic_score_gemma":0.9307426,"domain_scores_codex":[0.9985883,0.00003270425,0.0004702722,0.0002665707,0.0001677227,0.0004744881],"domain_scores_gemma":[0.9984955,0.0001042456,0.0004625696,0.0004118117,0.0003590465,0.0001668866],"domain_codex":null,"domain_gemma":null,"domain_candidate":null,"domain_consensus":null,"study_design_codex":"not_applicable","study_design_gemma":"not_applicable","study_design_scores_codex":[0.00005995054,0.00003880327,0.03433755,0.00004639418,0.0003311837,0.00007147722,0.002246848,0.001914987,0.0005057242,0.0947529,0.8208196,0.0448746],"study_design_scores_gemma":[0.0002451359,0.000007525227,0.01665172,0.000104794,0.00006531489,0.000008777639,0.001737715,0.001666312,0.00007059638,0.002733751,0.9765348,0.0001735875],"study_design_candidate":"not_applicable","study_design_consensus":"not_applicable","genre_codex":"commentary","genre_gemma":"empirical","genre_scores_codex":[0.318443,0.001689509,0.01386009,0.4632412,0.006208298,0.0010729,0.0008926266,0.0001036198,0.1944888],"genre_scores_gemma":[0.9582381,0.00001784405,0.0001075211,0.006233538,0.002005341,0.00005713955,0.0001109978,0.00002660966,0.03320294],"genre_candidate":"empirical","genre_consensus":null,"teacher_disagreement_score":0.6397951,"threshold_uncertainty_score":0.6572175,"prediction_status":"machine_predicted_unvalidated"},"machine_scores":{"provisional":true,"baseline":true,"maturity_gate_passed":false,"score_opus":0.01087821953799317,"score_gpt":0.2120746171684039,"score_spread":0.2011963976304107,"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."}}