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Record W4390292227 · doi:10.59403/ywh4qx

Critique of the Report of the Advisory Panel on Canada's international tax system

2009· article· en· W4390292227 on OpenAlexaboutno aff
Brian J. Arnold

Bibliographic record

VenueBulletin for international taxation · 2009
Typearticle
Languageen
FieldBusiness, Management and Accounting
TopicTaxation and Legal Issues
Canadian institutionsnot available
Fundersnot available
KeywordsCriticismLegislationInternational taxationDouble taxationAccountingTax reformDirect taxAdvisory committeePolitical scienceLaw and economicsEconomicsPublic administrationInternational tradePublic economicsBusinessLaw

Abstract

fetched live from OpenAlex

This article presents a critical analysis of the report of the Advisory Panel on Canada's System of International Taxation. The criticism is derived from the author's analysis in his 2009 book on reforming Canada's international tax system. The article focuses on three aspects of the report: taxation of the foreign-source income of Canadian corporations, deductibility of interest expenses, and tax administration and legislation. The article concludes that the report does not provide a thorough, analytically rigorous examination of the most difficult issues facing Canada's international tax system.

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 distilled prediction

Teacher imitation

Not calibrated prevalence, not ground truth. Human validation pending. Learned from the 10,348 direct Codex labels and 10,348 direct Gemma labels. Candidate is the union of thresholded teacher heads; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels or direct frontier model labels.

metaresearch head score (Codex)0.000
metaresearch head score (Gemma)0.002
Version: codex-gemma-dda1882f352aValidation 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 score0.747
Threshold uncertainty score0.949

Codex and Gemma teacher scores by category

CategoryCodexGemma
Metaresearch0.0000.002
Meta-epidemiology (narrow)0.0000.000
Meta-epidemiology (broad)0.0000.000
Bibliometrics0.0000.000
Science and technology studies0.0000.000
Scholarly communication0.0000.000
Open science0.0000.000
Research integrity0.0000.000
Insufficient payload (model declined to judge)0.0000.000

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 head0.016
GPT teacher head0.235
Teacher spread0.219 · 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 teacher head, 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

Citations1
Published2009
Admission routes1
Has abstractyes

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