Bibliographic record
Abstract
Australia has four anti-deferral regimes applicable to Australian residents that have interests in foreign entities. The regimes are (i) the controlled foreign companies (CFC) regime, (ii) the foreign investment fund (FIF) regime, (iii) the transferor trust regime, and (iv) the deemed present entitlement rules. The legislation enacting these regimes is among the most detailed and complex tax legislation in Australia. The regimes are not well coordinated, particularly the border between CFCs and FIFs, and the treatment of foreign trusts. They have different exemptions creating incentives for taxpayers to prefer one regime over another. The broad design of Australia's CFC rules largely follows that developed in pre-globalisation times, particularly by the United States and Canada. It is argued that the design does not adequately take account of the nature of the global economy today. The Australian Government has asked the Board of Taxation to, inter alia, examine ways in which the anti-deferral regimes can be better harmonised. This paper outlines the historical development of Australia's anti-deferral regimes and offers proposals for harmonisation.
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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 | 0.007 | 0.011 |
| Meta-epidemiology (narrow) | 0.000 | 0.001 |
| Meta-epidemiology (broad) | 0.000 | 0.001 |
| Bibliometrics | 0.002 | 0.001 |
| Science and technology studies | 0.003 | 0.002 |
| Scholarly communication | 0.003 | 0.002 |
| Open science | 0.002 | 0.004 |
| Research integrity | 0.003 | 0.004 |
| Insufficient payload (model declined to judge) | 0.003 | 0.001 |
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.
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".