Chapter 21: Canada: The Taxation of Pension Income under Canada’s Tax Treaty with Colombia – Reyes v. Canada
Bibliographic record
Abstract
Why this book? This book is a unique publication that gives 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 32 most important tax treaty cases that were decided around the world in 2019. 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 2020 is a valuable reference tool for anyone interested in tax treaty case law, including tax practitioners, multinational businesses, policymakers, tax administrators, judges and academics. Downloads Sample excerpt, including table of contents This book is part of the Tax Treaty Case Law around the Globe Series View other titles in the series Editor(s) Eric C.C.M. Kemmeren, Professor at the Fiscal Institute Tilburg of Tilburg University, Chairman of the Tax Economics Department of the Fiscal Institute Tilburg of Tilburg University and member of the Board of the European Tax College. Peter Essers, Professor at the Fiscal Institute Tilburg of Tilburg University, Chairman of the Tax Law Department of the Fiscal Institute Tilburg of Tilburg University and member of the Board of the European Tax College. Daniël S. Smit, Professor at the Fiscal Institute Tilburg of Tilburg University. Cihat Öner, Associate Professor at the Fiscal Institute Tilburg of Tilburg University. Michael Lang, Professor and Head of the Institute for Austrian and International Tax Law, WU (Vienna University of Economics and Business). Jeffrey Owens, Professor at the Institute for Austrian and International Tax Law, WU (Vienna University of Economics and Business) and Head of the Global Tax Policy Center at the Institute for Austrian and International Tax Law, WU. Pasquale Pistone, Professor at the Institute for Austrian and International Tax Law, WU (Vienna University of Economics and Business), Associate Professor at the University of Salerno and Academic Chairman of IBFD. Alexander Rust, Professor at the Institute for Austrian and International Tax Law, WU (Vienna University of Economics and Business). Josef Schuch, Professor at the Institute for Austrian and International Tax Law, WU (Vienna University of Economics and Business). Claus Staringer, Professor at the Institute for Austrian and International Tax Law, WU (Vienna University of Economics and Business). Alfred Storck, Professor at the Institute for Austrian and International Tax Law, WU (Vienna University of Economics and Business). Georg Kofler, Professor at the Institute for Austrian and International Tax Law, WU (Vienna University of Economics and Business). Karoline Spies, Professor at the Institute for Austrian and International Tax Law, WU (Vienna University of Economics and Business). Contributor(s) Ricardo García Antón, Paolo Arginelli, Philip Baker, Martin Berglund, Michael Dirkis, David G. Duff, Kasper Dziurdź, Guilherme Galdino, Esteban Montenegro Guillinta, M.J. Mart van Hulten, Guglielmo Maisto, Joana Mansilha, Cihat Öner, Katerina Pantazatou, Lysandre Papadopoulos, Cees Peters, Marilyne Sadowsky, Luís Eduardo Schoueri, Mirna Solange Screpante, D.P. Sengupta, Daniël S. Smit, A.J.A. Ton Stevens, Stan A. Stevens, Karolina Tetłak, Dinis Tracana, Anne Van de Vijver, Alvaro Villegas Aldazosa, 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 | 0.000 | 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 | 0.001 | 0.000 |
| Scholarly communication | 0.000 | 0.000 |
| Open science | 0.000 | 0.000 |
| Research integrity | 0.000 | 0.000 |
| Insufficient payload (model declined to judge) | 0.001 | 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 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".