Chapter 3: Canada: Corporate Residence and the Treaty Tiebreaker Rule – Landbouwbedrijf Backx B.V. v. Her Majesty The Queen
Bibliographic record
Abstract
Why this book?This book is a unique publication that provides a global overview of international tax disputes in respect of double tax conventions and thereby fills a gap in the area of tax treaty case law. It covers the 37 most important tax treaty cases that were decided around the world in 2021. The systematic structure of each chapter allows for the easy and efficient study and comparison of the various methods adopted for applying and interpreting tax treaties in different cases. With the continuously increasing importance of tax treaties, Tax Treaty Case Law around the Globe 2022 is a valuable reference tool for anyone interested in tax treaty case law, including tax practitioners, multinational businesses, policymakers, tax administrators, judges and academics.This book is part of the Tax Treaty Case Law around the Globe SeriesView other titles in the seriesDownloadsSample excerpt, including table of contentsList of Contributor(s)Ricardo García Antón, Hrvoje Arbutina, Eva Baekelant, Michael Beusch, Daniel W. Blum, Yariv Brauner, Renan Baleeiro, Michael Dirkis, Ana Paula Dourada, David G. Duff, Eivind Furuseth, Esteban Montenegro Guillinta, Søren Friis Hansen, Werner Haslehner, Johann Hattingh, Marjaana Helminen, Adolfo Martín Jiménez, Guglielmo Maisto, Karen Miller, Cihat Öner, Alexander Rust, Marilyne Sadowsky, Luís Eduardo Schoueri, Mirna Screpante, Moritz Seiler, D.P. Sengupta, Cesare Silvani, A.J.A. (Ton) Stevens, Karolina Tetlak, Anne Van de Vijver, Craig West.
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How this classification was reachedexpand
Full frame distilled prediction
Teacher imitationNot 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.
Codex and Gemma teacher scores by category
| Category | Codex | Gemma |
|---|---|---|
| Metaresearch | 0.001 | 0.000 |
| Meta-epidemiology (narrow) | 0.001 | 0.000 |
| Meta-epidemiology (broad) | 0.001 | 0.000 |
| Bibliometrics | 0.000 | 0.000 |
| Science and technology studies | 0.002 | 0.001 |
| Scholarly communication | 0.001 | 0.001 |
| Open science | 0.001 | 0.001 |
| Research integrity | 0.000 | 0.001 |
| Insufficient payload (model declined to judge) | 0.001 | 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 teacher head, 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".