Bibliographic record
Abstract
Permanent establishment (PE) is a tax treaty concept that raises the bar for taxation of foreign companies that do business in the United States. A PE is usually defined as a fixed place of business, like an office or factory. However, a PE can also be created in the absence of a fixed place of business by an agent if the agent is other than an agent of independent status. For linguistic convenience, such agents are usually called dependent agents. The rules regarding dependent and independent agents are typically set forth in separate paragraphs in a tax treaty, and dependent and independent agents are usually discussed and analyzed as if they were separate concepts. That approach is less than ideal because it leaves the reader to cobble together the dividing line between the two. This article illustrates a unified approach to the issue of agency PE using Article V of the current, 1980 U.S.-Canada tax treaty as a case study.
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 | 0.003 | 0.002 |
| Meta-epidemiology (narrow) | 0.001 | 0.001 |
| Meta-epidemiology (broad) | 0.001 | 0.001 |
| Bibliometrics | 0.004 | 0.004 |
| Science and technology studies | 0.010 | 0.016 |
| Scholarly communication | 0.011 | 0.009 |
| Open science | 0.002 | 0.004 |
| Research integrity | 0.007 | 0.008 |
| Insufficient payload (model declined to judge) | 0.005 | 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".