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Record W2066201371 · doi:10.1016/s2212-5671(14)00350-5

Comparison of European, Canadian and U.S. Formula Apportionment on Real Data

2014· article· en· W2066201371 on OpenAlex

Why this work is in the frame

A frame that forgets how it found something cannot be audited. These are the routes that admitted this work.

aboutThe title or abstract carries a Canadian signal from the geographic lexicon.
no affNo Canadian affiliation: this work is invisible to an affiliation-only frame.
No Canadian affiliation. An affiliation-only frame, the usual design, would never have seen this work. It is one of the works that make the case for inverting the frame.

Bibliographic record

VenueProcedia Economics and Finance · 2014
Typearticle
Languageen
FieldBusiness, Management and Accounting
TopicCorporate Taxation and Avoidance
Canadian institutionsnot available
Fundersnot available
KeywordsApportionmentHarmonizationDirectiveMember statesCorporate taxAccountingBase (topology)BusinessEconomicsRegional sciencePolitical sciencePublic economicsDouble taxationGeographyInternational economicsEuropean unionTax avoidanceLawComputer scienceMathematics

Abstract

fetched live from OpenAlex

The harmonization of the tax regime of EU Member States represents one possible way to intensify their economic integration. Tax harmonization by a Common Consolidated Corporate Tax Base constitutes a similar system to which has been used in Canada, USA or Switzerland since the last century. The present paper describes the principles of formulas apportionment which are used in Canada and the USA and proves different distribution of the tax base in comparison with the formula apportionment as published in the proposal to the Council Directive on a Common Consolidated Corporate Tax Base of 16 March 2011.

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.

Full frame distilled prediction

Teacher imitation

Not calibrated prevalence, not ground truth. Human validation pending. Learned from the 10,348 direct Codex labels and 10,348 direct Gemma labels. Candidate is the union of thresholded teacher heads; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels or direct frontier model labels.

metaresearch head score (Codex)0.000
metaresearch head score (Gemma)0.000
Version: codex-gemma-dda1882f352aValidation status: machine_predicted_unvalidated
Candidate categoriesnone
Consensus categoriesnone
DomainCandidate signal: none · Consensus signal: none
Study designCandidate signal: Not applicable · Consensus signal: none
GenreCandidate signal: Empirical · Consensus signal: Empirical
Teacher disagreement score0.603
Threshold uncertainty score0.500

Codex and Gemma teacher scores by category

CategoryCodexGemma
Metaresearch0.0000.000
Meta-epidemiology (narrow)0.0000.000
Meta-epidemiology (broad)0.0000.000
Bibliometrics0.0000.000
Science and technology studies0.0000.000
Scholarly communication0.0000.000
Open science0.0000.000
Research integrity0.0000.000
Insufficient payload (model declined to judge)0.0000.000

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.

Opus teacher head0.039
GPT teacher head0.231
Teacher spread0.192 · how far apart the two teachers sit on this one work
Validation statusscore_only:v0-immature-baseline · verbatim from the scoring run: score_only means the number may rank works, and no category label ships from it