MétaCan
Menu
Back to cohort
Record W4382585266 · doi:10.5206/uwojls.v14i2.14880

Deductibility of Surrogacy Payments in Canadian Tax Law

2023· article· en· W4382585266 on OpenAlexvenueaboutno aff
Tatiana Hulan

Bibliographic record

VenueWestern Journal of Legal Studies · 2023
Typearticle
Languageen
FieldSocial Sciences
TopicLegal Systems and Judicial Processes
Canadian institutionsnot available
Fundersnot available
KeywordsPaymentTax creditTax deductionIndirect taxValue-added taxBusinessTax reformDirect taxPublic economicsIncome taxDeductibleAd valorem taxState income taxLaw and economicsEconomicsFinanceActuarial scienceGross income

Abstract

fetched live from OpenAlex

Surrogacy arrangements in Canada are estimated to have increased by 400% in the last decade, in part due to the rising rates of infertility. Costs for these arrangements can be upwards of $100,000. Individuals and couples using a surrogate to expand their family have sought relief under the medical expense tax credit pursuant to section 118.2(2) or the adoption tax credit pursuant to section 118.01(2) of the Income Tax Act. The deductibility of these payments is a relatively new issue in Canadian tax law; however Canadian courts have consistently denied the deduction of surrogacy payments. The Tax Court of Canada has heard five cases on the matter and has denied the deduction in all four that have precedential value. Surrogates do not meet the definition of “patient” to qualify for the medical expense tax credit and are outside the scope of the adoption tax credit. This article canvases legal and policy arguments in favour of and against allowing surrogacy payments to be tax deductible. It proposes the creation of a new surrogacy expense tax credit, similar in design to the existing adoption tax credit.

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)0.007
metaresearch head score (Gemma)0.019
Version: metacan-v3-hybrid-931329e0061cValidation status: machine_predicted_unvalidated
Candidate categoriesnone
Consensus categoriesnone
DomainCandidate signal: none · Consensus signal: none
Study designCandidate signal: Theoretical or conceptual · Consensus signal: Theoretical or conceptual
GenreCandidate signal: Empirical · Consensus signal: none
Teacher disagreement score0.109
Threshold uncertainty score0.790

Distilled classifier scores by category (both heads)

CategoryCodexGemma
Metaresearch0.0070.019
Meta-epidemiology (narrow)0.0000.001
Meta-epidemiology (broad)0.0000.001
Bibliometrics0.0020.002
Science and technology studies0.0210.009
Scholarly communication0.0080.002
Open science0.0020.003
Research integrity0.0050.006
Insufficient payload (model declined to judge)0.0060.000

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.

Opus teacher head0.069
GPT teacher head0.388
Teacher spread0.318 · 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 designTheoretical or conceptual
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

Citations1
Published2023
Admission routes2
Has abstractyes

Explore more

Same venueWestern Journal of Legal StudiesSame topicLegal Systems and Judicial ProcessesFrench-language works237,207