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Record W2282220544

Commentary: 'Attending' University via the Internet

2013· article· en· W2282220544 on OpenAlexaffabout
Gabrielle St-Hilaire

Bibliographic record

VenueSSRN Electronic Journal · 2013
Typearticle
Languageen
FieldBusiness, Management and Accounting
TopicTaxation and Legal Issues
Canadian institutionsUniversity of Ottawa
Fundersnot available
KeywordsAgency (philosophy)InstitutionStatuteLegislationRevenuePolitical scienceLegislatureAttendanceThe InternetPublic administrationLawBusinessAccountingSociology
DOInot available

Abstract

fetched live from OpenAlex

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 distilled prediction

Teacher imitation

Not calibrated prevalence, not ground truth. Human validation pending. Learned from the 10,348 direct Codex labels and 10,348 direct Gemma labels. Candidate is the union of thresholded teacher heads; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels or direct frontier model labels.

metaresearch head score (Codex)0.000
metaresearch head score (Gemma)0.000
Version: codex-gemma-dda1882f352aValidation status: machine_predicted_unvalidated
Candidate categoriesInsufficient payload (model declined to judge)
Consensus categoriesnone
DomainCandidate signal: none · Consensus signal: none
Study designCandidate signal: Not applicable · Consensus signal: none
GenreCandidate signal: Empirical · Consensus signal: Empirical
Teacher disagreement score0.789
Threshold uncertainty score1.000

Codex and Gemma teacher scores by category

CategoryCodexGemma
Metaresearch0.0000.000
Meta-epidemiology (narrow)0.0000.000
Meta-epidemiology (broad)0.0000.000
Bibliometrics0.0000.000
Science and technology studies0.0000.000
Scholarly communication0.0000.001
Open science0.0000.000
Research integrity0.0000.001
Insufficient payload (model declined to judge)0.0010.001

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.

Opus teacher head0.006
GPT teacher head0.192
Teacher spread0.185 · how far apart the two teachers sit on this one work
Validation statusscore_only:v0-immature-baseline · verbatim from the scoring run: score_only means the number may rank works, and no category label ships from it

Classification

machine, unvalidated

Machine predicted; a candidate call from one teacher head, not a consensus.

Study designNot applicable
Domainnot available
GenreEmpirical

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".

Quick stats

Citations0
Published2013
Admission routes2
Has abstractyes

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