Balancing National Interests in the Taxation of Electronic Commerce Business Profits
Why this work is in the frame
A frame that forgets how it found something cannot be audited. These are the routes that admitted this work.
Bibliographic record
Abstract
This Article begins by exploring the issues surrounding the taxation of international electronic commerce (e-commerce) business profits. The United States Treasury Department and other national tax authorities are struggling to find mechanisms to collect the anticipated significant revenues derived from taxing e-commerce profits. Legal reform is likely required because the existing regime was set up to handle transfers of physical goods across borders. This Article discusses possible reform efforts to confront the challenges posed by cyberspace transactions that defy traditional conceptions of cross-border trade. The Treasury Department and most other national tax authorities insist on using traditional international tax principles. Since it is clear that any reform will require significant international cooperation, this Article proposes a framework for the taxation of e-commerce pofits that incorporates these traditional principles, but which also ensure that revenues are shared between the country where the e-commerce good or service is produced as well as the country where the good or service is consumed. The proposals hence represent a balanced compromise between the interests of countries that are either net exporters or net importers of e-commerce goods and services.
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.
Full frame distilled prediction
Teacher imitationNot 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.
Codex and Gemma teacher scores by category
| Category | Codex | Gemma |
|---|---|---|
| Metaresearch | 0.002 | 0.000 |
| Meta-epidemiology (narrow) | 0.000 | 0.000 |
| Meta-epidemiology (broad) | 0.000 | 0.000 |
| Bibliometrics | 0.000 | 0.001 |
| Science and technology studies | 0.000 | 0.000 |
| Scholarly communication | 0.000 | 0.001 |
| Open science | 0.000 | 0.000 |
| Research integrity | 0.000 | 0.001 |
| Insufficient payload (model declined to judge) | 0.000 | 0.000 |
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 it