Bibliographic record
Abstract
The curtain is coming down. The popcorn has grown stale. Hollywood has packed its bags and the trains are leaving for Canada, Australia, the United Kingdom and Eastern Europe. In recent years, the precipitous flight of film and television production from the U.S. has earned this phenomenon the moniker: “runaway production.” One of the great concerns of American voters and taxpayers has been the general decline of American manufacturing and industry. The United States is creeping toward a services economy where we import goods and produce very little domestically. The film industry has seen a disproportionate flight of its industry fall victim to globalization, but unlike other sectors of the economy, factors unique to media production have been both pushing and pulling films away from our shores. This article endeavors to show how the United States’ response to the problem of runaway production has been tepid. Section 199 of the Internal Revenue Code is the one of the current means of combating runaway production. It has been ineffective since its promulgation. Congress very recently expanded the scope of the provision; however, we have all seen this movie before. Even in its recently modified form, Section 199 is merely zoom lens when a wide-angle lens is more appropriate. I venture to give a solution that is comparable in force to competing international incentives, yet tailored to the general tax policy concerns of the U.S. Part II of this article provides a history of runaway film production and what factors have contributed to it, including a survey of international tax regimes that are designed to seduce filming to foreign sets. Part III outlines how the United States has responded to the issue in the form of ever-evolving tax incentives. However, Part IV will show how these incentives, including the most recent expansion of I.R.C. § 199 are not the sharp sword we need to combat the flight of films. In Part V, I venture a hypothetical tax incentive that may keep filming in the U.S. while remaining beneficial to taxpayers at large. Last, the article explores the factors that militate against any substantive progress in crafting an incentive that will keep the United States as a contender in the fight.
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 | 0.002 | 0.010 |
| Meta-epidemiology (narrow) | 0.001 | 0.000 |
| Meta-epidemiology (broad) | 0.000 | 0.000 |
| Bibliometrics | 0.001 | 0.001 |
| Science and technology studies | 0.006 | 0.005 |
| Scholarly communication | 0.013 | 0.011 |
| Open science | 0.001 | 0.005 |
| Research integrity | 0.003 | 0.007 |
| Insufficient payload (model declined to judge) | 0.060 | 0.015 |
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".