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Record W2997234576 · doi:10.32721/ctj.2019.67.4.ptp

Personal Tax Planning: Getting a GRIP on New Passive Investment Rules and Integration

2019· article· en· W2997234576 on OpenAlexvenueaboutno aff
Dino Infanti, Deepk Jaswalr, Sonam Toor

Bibliographic record

VenueCanadian Tax Journal/Revue fiscale canadienne · 2019
Typearticle
Languageen
FieldBusiness, Management and Accounting
TopicTaxation and Legal Issues
Canadian institutionsnot available
Fundersnot available
KeywordsCorporate taxLegislationDividendBusinessDouble taxationInvestment (military)Tax avoidanceEconomicsPublic economicsAccountingFinancePolitical scienceLaw

Abstract

fetched live from OpenAlex

This article discusses integration in the Canadian tax system and describes how legislation originating from changes announced in the 2018 federal budget affects Canadian-controlled private corporations. The authors point out that refundable dividend tax on hand is now split into two pools, one for eligible refundable dividend tax on hand and one for non-eligible refundable dividend tax on hand. As well, the authors discuss two recent changes to the small business deduction rules: (1) the reduction of the small business deduction where passive investment income exceeds a specified limit and (2) the expanded application of the rules for sharing the small business limit among corporations within a corporate group.

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)0.008
metaresearch head score (Gemma)0.017
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: Other · Consensus signal: Other
Teacher disagreement score0.066
Threshold uncertainty score0.476

Distilled classifier scores by category (both heads)

CategoryCodexGemma
Metaresearch0.0080.017
Meta-epidemiology (narrow)0.0010.001
Meta-epidemiology (broad)0.0000.001
Bibliometrics0.0020.004
Science and technology studies0.0090.007
Scholarly communication0.0080.006
Open science0.0030.003
Research integrity0.0020.008
Insufficient payload (model declined to judge)0.0110.002

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 head0.017
GPT teacher head0.200
Teacher spread0.183 · 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
GenreOther

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

Citations0
Published2019
Admission routes2
Has abstractyes

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