Bibliographic record
Abstract
The book is a study of the current state of international tax law and its application (or non-application) to electronic commerce in Canada, China, Hong Kong, Japan, Singapore, and the United States. Its purpose is to examine the extent to which current theories and principles of international taxation remain valid and the extent to which the fundamental issues need to be rethought in the age of electronic commerce. Chapter 12 argues that the existing concepts and principles have served the world well in the “old” economy, but decreasingly serve to carve up the international tax base in a reasonable and sustainable way in the “new” economy. I discuss why the concepts of corporate residence, characterization of income, source, and permanent establishment are increasingly difficult to apply. I also analyze why transfer-pricing rules are problematic in terms of economic theory, administrative efficiency, and the interpretation of article 9 of the model tax convention prepared by the Organisation for Economic Co-operation and Development (OECD).
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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 | 0.003 | 0.006 |
| Meta-epidemiology (narrow) | 0.000 | 0.000 |
| Meta-epidemiology (broad) | 0.000 | 0.001 |
| Bibliometrics | 0.001 | 0.002 |
| Science and technology studies | 0.003 | 0.010 |
| Scholarly communication | 0.006 | 0.006 |
| Open science | 0.001 | 0.003 |
| Research integrity | 0.002 | 0.005 |
| Insufficient payload (model declined to judge) | 0.006 | 0.001 |
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".