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Policy Forum: The Registered Charity Appeals Process—More Reasons (and a Few Proposals) for Reform

2024· article· en· W4401415475 on OpenAlexvenueaboutno aff
Kathryn Chan

Bibliographic record

VenueCanadian Tax Journal/Revue fiscale canadienne · 2024
Typearticle
Languageen
FieldSocial Sciences
TopicLegal Systems and Judicial Processes
Canadian institutionsnot available
Fundersnot available
KeywordsProcess (computing)Political sciencePublic administrationLaw and economicsComputer scienceSociology

Abstract

fetched live from OpenAlex

The current process of challenging decisions of the Canada Revenue Agency's Charities Directorate has significant shortcomings, which are well known within the field. A series of committees and scholars have urged Parliament to increase the transparency of the directorate's decision-making processes and create a more accessible appeal process for registered charities. In this article, the author discusses two developments that have made the case for reforming the charity appeals process even more compelling than before. The first is the Supreme Court of Canada's overhaul of the judicial review framework in <i>Canada (Minister of Citizenship and Immigration) v. Vavilov</i> (2019 SCC 65); the second is the trend toward public-law challenges to the registered charity regime in the superior courts. The author also outlines possible options for reform of the current Canadian model. Among other things, she considers whether elements of the English charity-law reference procedure could be accommodated within the existing registered charity regime in Canada's Income Tax Act.

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)0.002
metaresearch head score (Gemma)0.002
Version: codex-gemma-dda1882f352aValidation status: machine_predicted_unvalidated
Candidate categoriesScience and technology studies
Consensus categoriesnone
DomainCandidate signal: none · Consensus signal: none
Study designCandidate signal: Not applicable · Consensus signal: none
GenreCandidate signal: Empirical · Consensus signal: none
Teacher disagreement score0.920
Threshold uncertainty score0.999

Codex and Gemma teacher scores by category

CategoryCodexGemma
Metaresearch0.0020.002
Meta-epidemiology (narrow)0.0000.000
Meta-epidemiology (broad)0.0000.000
Bibliometrics0.0000.001
Science and technology studies0.0030.000
Scholarly communication0.0010.001
Open science0.0010.000
Research integrity0.0000.001
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 head0.028
GPT teacher head0.305
Teacher spread0.277 · 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
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

Citations0
Published2024
Admission routes2
Has abstractyes

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