The Unthinkable Policy Option? Key Design Issues Under a System of Full Consolidation
Bibliographic record
Abstract
In 2010, Canada’s Department of Finance initiated a consultation process to consider the possible introduction of a formal corporate group taxation system. A principal focus of the consultation process has been the type of group taxation system that would be best for Canada. The two most common alternatives that have been adopted in other countries are the loss transfer and full consolidation systems. The choice between these two systems is a difficult one. Nevertheless, provincial interest in a full consolidation regime is evident, especially as a means to address the interprovincial allocation issue.The purpose of this article is to provide an in-depth comparative analysis of the consolidation regimes adopted in eight countries: Australia, France, Italy, Japan, the Netherlands, New Zealand, Spain, and the United States. These are the countries that, by the end of 2009, had introduced full consolidation regimes providing for both intragroup loss offsets and tax-free asset transfers. The article critically compares the alternative policy options with respect to the design features and key structural elements of the eight selected consolidation regimes in an attempt to identify a model regime or template that might serve as a starting point for a Canadian system. In response to concern about the perceived complexity of a consolidation regime, the article ranks the eight consolidation regimes by applying a complexity index. This exercise is designed to highlight two aspects of the issue: first, the eight regimes represent a spectrum of varying degrees of complexity, indicating that a consolidation regime need not be as complex as the Australian and US models; and second, the complexity of a regime depends to a large extent on the policy choices with respect to the key structural elements.
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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 | 0.022 | 0.027 |
| Meta-epidemiology (narrow) | 0.001 | 0.001 |
| Meta-epidemiology (broad) | 0.001 | 0.001 |
| Bibliometrics | 0.001 | 0.002 |
| Science and technology studies | 0.005 | 0.009 |
| Scholarly communication | 0.016 | 0.007 |
| Open science | 0.003 | 0.005 |
| Research integrity | 0.004 | 0.004 |
| Insufficient payload (model declined to judge) | 0.005 | 0.000 |
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".