{"id":"W7006338179","doi":"","title":"Treaty shopping and the abuse of income tax conventions","year":2005,"lang":"en","type":"dissertation","venue":"eScholarship@McGill (McGill)","topic":"Corporate Taxation and Avoidance","field":"Business, Management and Accounting","cited_by":0,"is_retracted":false,"has_abstract":true,"ca_institutions":"","funders":"University of Toronto; McGill University","keywords":"Tax treaty; Treaty; Legitimacy; Double taxation; Tax avoidance; International taxation; Tax law","routes":{"ca_aff":false,"ca_fund":true,"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":[0.004276441,0.0001771685,0.0002987461,0.001967993,0.01230798,0.01281024,0.0008109157,0.002740978,0.01978461],"category_scores_gemma":[0.01063951,0.0003178244,0.0003164034,0.004163169,0.01529913,0.005435005,0.004807895,0.00350411,0.001410111],"about_ca_system_candidate":false,"about_ca_system_consensus":false,"about_ca_system_score_codex":0.01055653,"about_ca_system_score_gemma":0.008490941,"about_ca_topic_candidate":false,"about_ca_topic_consensus":false,"about_ca_topic_score_codex":0.05112571,"about_ca_topic_score_gemma":0.08490108,"domain_scores_codex":[0.9938381,0.00296816,0.0001952011,0.0003148991,0.001278822,0.001404736],"domain_scores_gemma":[0.9949961,0.002225551,0.0008614475,0.0007038205,0.0007683451,0.000444698],"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":[0.00001175953,0.0000141576,0.0009561416,0.000010148,0.00000275875,0.00005408873,0.007708151,0.00004134053,0.00002978513,0.9720128,0.00998432,0.009174579],"study_design_scores_gemma":[0.00003129579,0.00002772082,0.01063814,0.0003264217,0.0000165813,0.0001809432,0.02105696,0.0002908051,0.0002878374,0.1717314,0.7953675,0.00004435092],"study_design_candidate":"theoretical_or_conceptual","study_design_consensus":"theoretical_or_conceptual","genre_codex":"other","genre_gemma":"empirical","genre_scores_codex":[0.05253159,0.002201747,0.0008216068,0.01685225,0.0001589865,0.00001716132,0.00006183844,0.00002390931,0.927331],"genre_scores_gemma":[0.7422541,0.00202094,0.0004455671,0.004608142,0.0001502416,0.00003838491,0.00005804245,0.00007204236,0.2503525],"genre_candidate":"empirical","genre_consensus":null,"teacher_disagreement_score":0.05112571,"threshold_uncertainty_score":0.1016563,"prediction_status":"machine_predicted_unvalidated"},"machine_scores":{"provisional":true,"baseline":true,"maturity_gate_passed":false,"score_opus":0.01477559647289383,"score_gpt":0.2213795302098067,"score_spread":0.2066039337369129,"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."}}