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Record W4396728653 · doi:10.59403/3mak8sp008

Chapter 8: Canada: Judicial Review of Taxpayer’s Request for Competent Authority Assistance under Canada-United States Tax Treaty

2014· book-chapter· en· W4396728653 on OpenAlexaboutno aff
David G. Duff

Bibliographic record

VenueTax treaty case law around the globe. · 2014
Typebook-chapter
Languageen
FieldBusiness, Management and Accounting
TopicTaxation and Legal Issues
Canadian institutionsnot available
Fundersnot available
KeywordsTaxpayerTax treatyTreatyPolitical scienceLawBusinessTax lawDouble taxation

Abstract

fetched live from OpenAlex

Why this book? This book provides a unique and comprehensive global overview of international tax disputes on double tax conventions, thereby filling a gap in the area of tax treaty case law. It covers the 39 most important tax treaty cases that were decided in 2013 around the world. The systematic structure of each case allows easy and efficient comparison of the varying application and interpretation of tax treaties in different regimes. With the continuously increasing importance of tax treaties, Tax Treaty Case Law around the Globe 2014 is a valuable reference tool for anyone interested in tax treaty case law. This book is of interest to tax practitioners, multinational enterprises, 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 Kemmeren, professor of international tax law and international taxation at and chairman of the Tax Economics Department of the Fiscal Institute Tilburg of Tilburg University, the Netherlands and member of the board of the European Tax College. Daniël Smit, Ph.D. in international tax law and European taxation at the Fiscal Institute Tilburg of Tilburg University, the Netherlands. Peter Essers, professor of tax law at and chairman of the Tax Law Department of the Fiscal Institute Tilburg of Tilburg University, the Netherlands and member of the board of the European Tax College. Michael Lang, professor at 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, Italy and Academic Chairman 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). Contributor(s) Philip Baker, Tomas Balco, Cédric Ballenegger, Martin Berglund, Stefano Bernasconi, Michael Beusch, Yariv Brauner, José Manuel Calderón Carrero, Graeme Cooper, Tsilly Dagan, Luc De Broe, César Augusto Domínguez Crespo, David Duff, Kasper Dziurdź, Søren Friis Hansen, Marjaana Helminen, Eric C.C.M. Kemmeren, Patrick Knörzer, Michael Lang, Guglielmo Maisto, Alexandre Maitrot de la Motte, Adolfo Martín Jiménez, Danuše Nerudová, João Nogueira, Alexander Rust, Jacques Sasseville, Dikshit Prasad Sengupta, Daniël Smit, Alfred Storck, Danil Vladimirovich Vinnitskiy, Martin Wenz, Billur Yalti, Salome Zimmermann.

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)0.001
metaresearch head score (Gemma)0.000
Version: codex-gemma-dda1882f352aValidation status: machine_predicted_unvalidated
Candidate categoriesMeta-epidemiology (narrow)
Consensus categoriesnone
DomainCandidate signal: none · Consensus signal: none
Study designCandidate signal: Not applicable · Consensus signal: none
GenreCandidate signal: Other · Consensus signal: none
Teacher disagreement score0.890
Threshold uncertainty score1.000

Codex and Gemma teacher scores by category

CategoryCodexGemma
Metaresearch0.0010.000
Meta-epidemiology (narrow)0.0010.001
Meta-epidemiology (broad)0.0010.000
Bibliometrics0.0000.000
Science and technology studies0.0010.000
Scholarly communication0.0000.000
Open science0.0000.000
Research integrity0.0000.000
Insufficient payload (model declined to judge)0.0010.000

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 head0.027
GPT teacher head0.237
Teacher spread0.210 · 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.

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
Published2014
Admission routes1
Has abstractyes

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