Bibliographic record
Abstract
The early tax deductions for post-secondary students required that students studying within Canada only be enrolled in an educational institution in Canada, whereas students outside Canada were required to show full-time to an university. Surely when the statutory double-standard was created in the 1960s, legislators had not anticipated that students would be accessing international institutions on-line from within Canada. This article discusses whether tax relief is available to Canadian students taking a full time course load online at a foreign institution. The Tax Court of Canada and the Canada Revenue Agency have slowly evolved to take a broad interpretation of attendance so as not to require that on-line students physically attend an institution abroad to qualify for the tax credit. While the meaning of legislation must evolve with the evolution of society, there comes a point when the wording of a provision cannot accommodate a situation inconceivable when the provision was drafted. The author concludes that the legislature should have amended the statute to offer guidance to the Tax Court and Canada Revenue Agency.
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 | 0.006 | 0.036 |
| Meta-epidemiology (narrow) | 0.001 | 0.001 |
| Meta-epidemiology (broad) | 0.002 | 0.002 |
| Bibliometrics | 0.001 | 0.002 |
| Science and technology studies | 0.013 | 0.010 |
| Scholarly communication | 0.006 | 0.008 |
| Open science | 0.006 | 0.003 |
| Research integrity | 0.092 | 0.087 |
| Insufficient payload (model declined to judge) | 0.009 | 0.006 |
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".