{"id":"W4411451882","doi":"10.2139/ssrn.5310130","title":"Reforming the Foreign Tax Credit, Subpart F, and GILTI in Light of Pillar Two","year":2025,"lang":"en","type":"article","venue":"SSRN Electronic Journal","topic":"Taxation and Legal Issues","field":"Business, Management and Accounting","cited_by":0,"is_retracted":false,"has_abstract":false,"ca_institutions":"Thomson Reuters (Canada)","funders":"","keywords":"Pillar; Business; Economics; Mechanical engineering; Engineering","routes":{"ca_aff":true,"ca_fund":false,"ca_venue":false,"about_ca":false,"invisible_to_affiliation_only":false},"retraction":null,"screen":null,"direct_labels":[],"prediction":{"model_version":"metacan-v3-hybrid-931329e0061c","candidate_categories":[],"consensus_categories":[],"category_scores_codex":[0.003950368,0.0006052534,0.0006955078,0.00201482,0.0031525,0.00677607,0.002094484,0.005766605,0.01635021],"category_scores_gemma":[0.01134321,0.0002929575,0.0007378359,0.001341013,0.002601204,0.002921345,0.002680365,0.007920912,0.00267086],"about_ca_system_candidate":false,"about_ca_system_consensus":false,"about_ca_system_score_codex":0.007392894,"about_ca_system_score_gemma":0.01559384,"about_ca_topic_candidate":false,"about_ca_topic_consensus":false,"about_ca_topic_score_codex":0.06342515,"about_ca_topic_score_gemma":0.07701454,"domain_scores_codex":[0.9975103,0.0002817536,0.00008975815,0.0004876163,0.0008707871,0.0007597263],"domain_scores_gemma":[0.9964539,0.0005991788,0.0002495822,0.0006752809,0.00122551,0.0007966419],"domain_codex":null,"domain_gemma":null,"domain_candidate":null,"domain_consensus":null,"study_design_codex":"theoretical_or_conceptual","study_design_gemma":"theoretical_or_conceptual","study_design_scores_codex":[0.0002605336,0.0001744026,0.005120719,0.00009244946,0.00004179795,0.0002728742,0.0009042762,0.001277072,0.001012145,0.8261377,0.1115837,0.05312224],"study_design_scores_gemma":[0.0003786456,0.0003654797,0.01535321,0.000408502,0.000127978,0.0004090802,0.001077179,0.005279174,0.003730091,0.2031884,0.7695243,0.0001579121],"study_design_candidate":"theoretical_or_conceptual","study_design_consensus":"theoretical_or_conceptual","genre_codex":"other","genre_gemma":"empirical","genre_scores_codex":[0.138547,0.002303926,0.02085885,0.08969429,0.007321544,0.0009885037,0.001633654,0.0008770194,0.7377751],"genre_scores_gemma":[0.5663747,0.0009459383,0.01151675,0.03385673,0.002146133,0.0004846073,0.0006326547,0.0002681677,0.3837743],"genre_candidate":"empirical","genre_consensus":null,"teacher_disagreement_score":0.06342515,"threshold_uncertainty_score":0.126112,"prediction_status":"machine_predicted_unvalidated"},"machine_scores":{"provisional":true,"baseline":true,"maturity_gate_passed":false,"score_opus":0.0060803193097965,"score_gpt":0.2306748878272295,"score_spread":0.224594568517433,"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."}}