Some implications of the Canadian tax law on foreign investments in Canada : a German perspective
Bibliographic record
Abstract
Canada is one of the countries depending on foreign investment to a fairly high extent. After some time of concern about foreign investment¹ the Foreign Investment Review Act (FIRA) was implemented.² With the federal election in 1984 the Canadian government took the stand in favour of foreign investment again and changed FIRA to a more positive "Investment Canada". Anyway, the control of foreign investment should be seen only as part of a larger economic policy, which determines the economic criteria for investment decisions. One of these criteria is the Canadian tax law. And as one example, prior to 1980, all private corporations were entitled to the refundable tax in respect of their investment income. A first limitation was introduced in October of 1973, whereby corporations other than Canadian-controlled-private corporations were denied any refundable tax in respect of income from real property for taxation years commenced after 1979. Finally, as a result of the November 12, 1981 budget, for taxation years commenced after that date, investment income no longer "earns" refundable tax unless the corporation was a Canadian-controlled-private corporation throughout the relevant taxation year. The Canadian taxation of residents and non-residents in Canada, including the taxation of Canadian and non-Canadian-controlled companies and branches of foreign companies, is unequal and discriminating. This thesis will give some ideas about the Canadian taxation of foreign investment in Canada, referring sometimes to the Canadian-German Double Tax Convention as well as the O.E.C.D. Model Double Tax Convention. Since tax planning is a part of general economic investment decisions, the taxation of foreign investments will be evaluated in relation to other investment criteria for investments in Canada. As it will become obvious, there are reasons in favour of the Canadian tax policy on one hand and reasons against it on the other hand. As a conclusion, I am of the opinion that it is worthwhile to consider changes in the taxation of foreign investment.
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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 | 0.002 | 0.004 |
| Meta-epidemiology (narrow) | 0.001 | 0.001 |
| Meta-epidemiology (broad) | 0.001 | 0.001 |
| Bibliometrics | 0.003 | 0.006 |
| Science and technology studies | 0.019 | 0.010 |
| Scholarly communication | 0.012 | 0.003 |
| Open science | 0.002 | 0.002 |
| Research integrity | 0.006 | 0.005 |
| Insufficient payload (model declined to judge) | 0.007 | 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".