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Record W2604645948

BEPS and the New International Tax Order

2016· article· en· W2604645948 on OpenAlexaff
Allison Christians

Bibliographic record

VenueeYLS (Yale Law School) · 2016
Typearticle
Languageen
FieldBusiness, Management and Accounting
TopicTaxation and Legal Issues
Canadian institutionsMcGill University
Fundersnot available
KeywordsBase erosion and profit shiftingMultinational corporationTax avoidanceOrder (exchange)Status quoOptimismPessimismTax policyTax reformPublic economicsPolitical scienceEconomicsWorld orderBusinessLaw and economicsMarket economyLawFinance
DOInot available

Abstract

fetched live from OpenAlex

Across the globe, banks are flagging accounts with indicia indicating their owners may be "US Persons", making it possible for the United States to enforce its taxation of nonresident citizens extraterritorially for the first time in history. The indicia method constitutes a mining expedition for US citizens carried out by foreign banks and governments. Establishing a tax jurisdiction in this manner is unprecedented, enlisting major foreign assistance to dramatically expand the enforcement of the U.S. tax jurisdiction over a globally dispersed population, after a century of neglect and apparent indifference. While supporting effective information exchange as to residents aligns with globally accepted tax jurisdiction norms, the reach to nonresident US citizens is not.[...]The international community would be justified to, at minimum, insist that the United States catalogue its own taxpayer population, inform this population of its status, and educate it of the attendant obligations, before turning to other countries to assist in the task.

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 imitation

Not 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.

metaresearch head score (Codex)0.003
metaresearch head score (Gemma)0.010
Version: metacan-v3-hybrid-931329e0061cValidation status: machine_predicted_unvalidated
Candidate categoriesnone
Consensus categoriesnone
DomainCandidate signal: none · Consensus signal: none
Study designCandidate signal: Not applicable · Consensus signal: none
GenreCandidate signal: Empirical · Consensus signal: none
Teacher disagreement score0.048
Threshold uncertainty score0.126

Distilled classifier scores by category (both heads)

CategoryCodexGemma
Metaresearch0.0030.010
Meta-epidemiology (narrow)0.0000.000
Meta-epidemiology (broad)0.0000.000
Bibliometrics0.0020.002
Science and technology studies0.0060.005
Scholarly communication0.0130.009
Open science0.0010.004
Research integrity0.0050.011
Insufficient payload (model declined to judge)0.0380.008

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 head0.011
GPT teacher head0.229
Teacher spread0.218 · 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 source (direct Gemma or distilled Codex), not a consensus.

The models applied no category: nothing in the taxonomy fit this work.
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

Citations49
Published2016
Admission routes1
Has abstractyes

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