Bibliographic record
Abstract
Section 31 of the Income Tax Act, which limits the ability of taxpayers to use farm losses to offset income from other sources, imposes a special restriction on farmers. The restriction is imposed where farming, itself or in combination with another source, is not the taxpayer’s chief source of income. This frequently-litigated section has a long history of unpredictability and inconsistency. This is partially due to the vagueness of the text of the provision, and so when the Supreme Court of Canada provided guidance on the section in Moldowan v. The Queen, one might have expected this to have resulted in more consistency in the case law. Unfortunately, courts have continued to struggle with section 31, with some cases interpreting it expansively and others very restrictively. The most recent cases indicate that there is the potential for arriving at a middle ground between the two extremes, although there are still many unsettled issues. Specific suggestions for ways the courts could clarify the law are provided. However, significant problems with section 31 are still likely to persist, and therefore policy makers are encouraged to consider amending or repealing section 31.
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 | 0.004 |
| Meta-epidemiology (narrow) | 0.000 | 0.000 |
| Meta-epidemiology (broad) | 0.000 | 0.000 |
| Bibliometrics | 0.000 | 0.000 |
| Science and technology studies | 0.007 | 0.004 |
| Scholarly communication | 0.005 | 0.002 |
| Open science | 0.001 | 0.003 |
| Research integrity | 0.005 | 0.007 |
| Insufficient payload (model declined to judge) | 0.003 | 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 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".