Applying the Canadian “reasonable expectation of profit” test to a section 80M(1)(d) reportable arrangement
Bibliographic record
Abstract
A section 80M(1)(d) reportable arrangement is defined in the Income Tax Act 58 of 1962, as amended, and contains the reasonable expectation of a pre‐tax profit requirement. Such an arrangement must be reported to the Commissioner of the South African Revenue Service within 60 days. Failure to do so can result in a R1 million penalty. It is submitted that this requirement is subjective because of a lack of indigenous litigation and implementation guidelines. The Canadian reasonable expectation of profit (REOP) test may be of value to formulate objective standards against which to apply the section 80M(1)(d) reportable arrangement.
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 | 0.038 | 0.188 |
| Meta-epidemiology (narrow) | 0.001 | 0.001 |
| Meta-epidemiology (broad) | 0.001 | 0.002 |
| Bibliometrics | 0.004 | 0.003 |
| Science and technology studies | 0.013 | 0.010 |
| Scholarly communication | 0.010 | 0.004 |
| Open science | 0.006 | 0.005 |
| Research integrity | 0.013 | 0.010 |
| Insufficient payload (model declined to judge) | 0.020 | 0.004 |
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".