International Tax Planning: The Fallout from Alta Energy Luxembourg—The Application of GAAR to Tax Treaties
Bibliographic record
Abstract
This article examines three factors that were influential in the Supreme Court’s 2021 decision in Canada v. Alta Energy Luxembourg SARL with respect to the potential application of the general anti-avoidance rule to the Canada-Luxembourg tax treaty: (1) the presumption that the contracting states know about each other’s domestic income tax system, (2) the dual nature of tax treaties as statutes and treaties, and (3) the theory of economic allegiance. It argues that, irrespective of whether one considers the court’s decision to be correct or incorrect, the court did not understand or apply these factors properly.
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How this classification was reachedexpand
Full frame machine prediction
Teacher imitationNot calibrated prevalence, not ground truth. Human validation pending. The Gemma side is a direct model label for every work in the frame, read from the title-only record. The Codex side is a classifier learned from the 10,348 direct Codex labels and calibrated to design-weighted sample rates; fields without enough sample support carry no Codex call. Candidate is the union of the two sides; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels.
Distilled classifier scores by category (both heads)
| Category | Codex | Gemma |
|---|---|---|
| Metaresearch | 0.005 | 0.005 |
| Meta-epidemiology (narrow) | 0.001 | 0.000 |
| Meta-epidemiology (broad) | 0.001 | 0.001 |
| Bibliometrics | 0.001 | 0.002 |
| Science and technology studies | 0.007 | 0.005 |
| Scholarly communication | 0.007 | 0.002 |
| Open science | 0.001 | 0.003 |
| Research integrity | 0.004 | 0.009 |
| Insufficient payload (model declined to judge) | 0.006 | 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 source (direct Gemma or distilled Codex), 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".