Bibliographic record
Abstract
This article examines how Indigenous Settlement Trusts (“Settlement Trusts”), established for the benefit of First Nations, are affected by the Income Tax Act (“Tax Act”). I argue that Settlement Trusts should be taxed differently than other personal trusts under the Tax Act. Currently, a Settlement Trust is taxed just as any other trust—as an individual pursuant to section 104(2) of the Tax Act—regardless of whether distinguished circumstances exist, as in the case of Indian Act-recognized Bands. This means that revenues are taxed at the top personal marginal tax rate. As such, the Settlement Trust relies upon the application of section 75(2) of the Tax Act to attribute revenues that remain in the Trust to the Band. The revenues are then tax exempt, pursuant to section 149(1)(c) of the Tax Act, because the Canada Revenue Agency’s administrative position is that Bands are public bodies performing a function of government in Canada. Ultimately, Bands face unnecessary administrative processes and costs from having Settlement Trusts taxed in this manner. I conclude that the Federal government should amend the Tax Act to exempt Settlement Trust revenues from being taxed under the general trust tax provisions so that administrative costs and processes for Bands will be eliminated or at least minimized. Bands could then claim Settlement Trust revenues directly in the same manner that they claim all other Band revenues.
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 | 0.004 | 0.008 |
| Meta-epidemiology (narrow) | 0.000 | 0.000 |
| Meta-epidemiology (broad) | 0.000 | 0.000 |
| Bibliometrics | 0.002 | 0.002 |
| Science and technology studies | 0.006 | 0.026 |
| Scholarly communication | 0.008 | 0.008 |
| Open science | 0.002 | 0.003 |
| Research integrity | 0.004 | 0.006 |
| Insufficient payload (model declined to judge) | 0.002 | 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".