Bibliographic record
Abstract
This paper explores the extent to which international tax law is more than the sum of its parts. It does so by examining three recent legal/policy decisions. The 2006 judgement of the Tax Court of Canada in MIL Investments decided that a statutory general anti-avoidance rule of interpretation does not operate to bar the practice of treaty shopping for corporate residence; the 2008 judgement of the United States Tax Court in Jameison determined that the alternative minimum tax credit limitation trumps the Canada-United States tax treaty foreign tax credit as the last-in-time enactment; and the Internationally Agreed Tax Standards issued by the OECD seek to implement a coordinated international standard for tax reporting. These decisions demonstrate that although tax treaty networks and a centralized OECD structure have been put in place, the interpretation and application of these instruments reflect much international law thinking in that they invariably circle back to unilateral state policy.
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 | 0.002 | 0.004 |
| Meta-epidemiology (narrow) | 0.000 | 0.000 |
| Meta-epidemiology (broad) | 0.000 | 0.000 |
| Bibliometrics | 0.002 | 0.002 |
| Science and technology studies | 0.003 | 0.008 |
| Scholarly communication | 0.008 | 0.008 |
| Open science | 0.001 | 0.004 |
| Research integrity | 0.002 | 0.006 |
| Insufficient payload (model declined to judge) | 0.020 | 0.003 |
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".