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Record W54969692 · doi:10.53300/001c.6741

Turning gambling silver into tax gold?

2013· article· en· W54969692 on OpenAlexaboutno aff
John Tretola

Bibliographic record

VenueRevenue Law Journal · 2013
Typearticle
Languageen
FieldSocial Sciences
TopicLegal Education and Practice Innovations
Canadian institutionsnot available
Fundersnot available
KeywordsClubPublicityTax lawTax avoidanceAccounts payableValue-added taxIndirect taxOrder (exchange)EconomicsAdvertisingLaw and economicsTax reformBusinessPublic economicsLawMarketingFinancePolitical sciencePaymentMedicine

Abstract

fetched live from OpenAlex

This paper is on the topic of gambling winnings and how silver (coin/money) can sometimes, if the correct set of circumstances exist, be turned into tax gold (tax payable to the Australian Tax Office). This is a topical issue due to some recent publicity in Australia about the so called Punters’ Club and their reported annual profit of $50 million gained from some $2 billion worth of bets placed annually and how the Australian Tax Office (ATO) is looking to tax the 19 identified members of this ‘club’ on their respective share of these winnings. These club members are of course choosing to ‘gamble’ against the ATO that they should not be taxed. The paper looks at the various approaches taken by Australian courts over the last century to the issue of whether gambling wins are assessable and highlights that of critical importance to the resolution of this issue is whether the gambling activities are carried on in the form of a business activity in a systematic and organised manner and whether the gambling activities involve a significant element of skill as opposed to mere random outcomes. The paper also considers the approaches to gambling cases taken in other similar tax law jurisdictions to Australia, such as the United Kingdom, Canada and New Zealand, in order to reveal common threads applicable to judgments across these different jurisdictions. Based on the principles of case law identified, the paper also considers the likely ‘chances’ of the Punters’ Club’s success in its arguments against the ATO.

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)0.001
Version: codex-gemma-dda1882f352aValidation status: machine_predicted_unvalidated
Candidate categoriesInsufficient payload (model declined to judge)
Consensus categoriesnone
DomainCandidate signal: none · Consensus signal: none
Study designCandidate signal: Not applicable · Consensus signal: none
GenreCandidate signal: Empirical · Consensus signal: Empirical
Teacher disagreement score0.701
Threshold uncertainty score0.999

Codex and Gemma teacher scores by category

CategoryCodexGemma
Metaresearch0.0010.001
Meta-epidemiology (narrow)0.0000.000
Meta-epidemiology (broad)0.0000.000
Bibliometrics0.0000.000
Science and technology studies0.0010.000
Scholarly communication0.0010.001
Open science0.0000.000
Research integrity0.0000.001
Insufficient payload (model declined to judge)0.0020.001

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.

Opus teacher head0.045
GPT teacher head0.381
Teacher spread0.336 · 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
Published2013
Admission routes1
Has abstractyes

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