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Record W4410236107 · doi:10.32721/ctj.2025.73.1.itp

International Tax Planning: The Fallout from Alta Energy Luxembourg—The Application of GAAR to Tax Treaties

2025· article· en· W4410236107 on OpenAlexvenueaboutno aff
Brian J. Arnold

Bibliographic record

VenueCanadian Tax Journal/Revue fiscale canadienne · 2025
Typearticle
Languageen
FieldBusiness, Management and Accounting
TopicTaxation and Legal Issues
Canadian institutionsnot available
Fundersnot available
KeywordsTax planningInternational tradeBusinessInternational economicsPolitical scienceDouble taxationEconomicsLawTax avoidance

Abstract

fetched live from OpenAlex

This article examines three factors that were influential in the Supreme Court’s 2021 decision in <i>Canada v. Alta Energy Luxembourg SARL</i> 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.

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)0.000
metaresearch head score (Gemma)0.000
Version: codex-gemma-dda1882f352aValidation status: machine_predicted_unvalidated
Candidate categoriesnone
Consensus categoriesnone
DomainCandidate signal: none · Consensus signal: none
Study designCandidate signal: Not applicable · Consensus signal: Not applicable
GenreCandidate signal: Empirical · Consensus signal: none
Teacher disagreement score0.640
Threshold uncertainty score0.657

Codex and Gemma teacher scores by category

CategoryCodexGemma
Metaresearch0.0000.000
Meta-epidemiology (narrow)0.0000.000
Meta-epidemiology (broad)0.0000.000
Bibliometrics0.0010.001
Science and technology studies0.0010.000
Scholarly communication0.0000.000
Open science0.0010.000
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 head0.011
GPT teacher head0.212
Teacher spread0.201 · 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.

The models applied no category: nothing in the taxonomy fit this work.
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

Citations1
Published2025
Admission routes2
Has abstractyes

Explore more

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