Bibliographic record
Abstract
In October 2012, the Federal Court of Appeal ruled in Johnson v Canada that a Ponzi scheme can be a source of income for a participant, and is therefore subject to tax. Leave to appeal to the Supreme Court of Canada was refused. Johnson argued in the Tax Court of Canada that the receipts were not subject to tax because they were not income from a source per section 3 of the Income Tax Act. The Tax Court applied the principle and indicia set out in Cranswick in determining whether the applicant's received amounts were “income from a source”. The Tax Court found that, as nothing was invested and nothing was actually earned, the capital investment was not the source of the amounts received. The Federal Court of Appeal disagreed, on a different conception of the facts. The returns on the scheme were taxable as income from a source – namely, property. The Federal Court of Appeal noted that a participant in a Ponzi scheme whose profits are taxable might, in the appropriate circumstances, be allowed to deduct related losses. It was hoped that the Supreme Court of Canada would allow Ms. Johnson's application for leave to appeal and clarify the application of the problematic wording in Hammill, the taxability of returns of “investors” who profit from Ponzi schemes, and the scope of section 3 and paragraph 3(a) of the Income Tax Act.
Fetched live from OpenAlex and de-inverted. Abstracts are not stored in this database: the inverted indexes are 8.6 GB of the frame’s 9.3 GB of text, and the host has 13 GB free.
How this classification was reachedexpand
Full frame machine prediction
Teacher imitationNot calibrated prevalence, not ground truth. Human validation pending. The Gemma side is a direct model label for every work in the frame, read from the title-only record. The Codex side is a classifier learned from the 10,348 direct Codex labels and calibrated to design-weighted sample rates; fields without enough sample support carry no Codex call. Candidate is the union of the two sides; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels.
Distilled classifier scores by category (both heads)
| Category | Codex | Gemma |
|---|---|---|
| Metaresearch | 0.004 | 0.010 |
| Meta-epidemiology (narrow) | 0.000 | 0.001 |
| Meta-epidemiology (broad) | 0.000 | 0.001 |
| Bibliometrics | 0.001 | 0.001 |
| Science and technology studies | 0.005 | 0.004 |
| Scholarly communication | 0.005 | 0.004 |
| Open science | 0.001 | 0.005 |
| Research integrity | 0.004 | 0.005 |
| Insufficient payload (model declined to judge) | 0.023 | 0.002 |
Machine scores (provisional)
The two teacher heads of the student model, read on this work. A score orders the frame for review; it never asserts a category, and the validation status ships verbatim with every row.
Baseline scores from an immature model (maturity gate not passed, 7 training rounds). Scores rank; they never assert a category.
score_only:v0-immature-baseline · verbatim from the scoring run: score_only means the number may rank works, and no category label ships from itClassification
machine, unvalidatedMachine predicted; a candidate call from one source (direct Gemma or distilled Codex), not a consensus.
How this classification was reached, model by model and score by score, is at the end of the page under "How this classification was reached".