The Canada Revenue Agency’s Implementation of First Nation-Canada Tax Administration Agreements: An Analysis of First Nation Sovereignty and Sui Generis Legal Status
Bibliographic record
Abstract
This thesis is anchored in a de-colonization theoretical and historical framework. It poses a narrow question in order to address a broader concern about First Nation sovereignty: Does the Canada Revenue Agency’s “same treatment” policy and practice towards First Nation tax filers and social benefit claimants comply with the Supreme Court of Canada’s sui generis common law principle, section 35 of the Canadian Constitution Act, 1982, and the United Nations Declaration on the Rights of Indigenous Peoples? This question is used as an indicator of First Nation sovereignty. A conceptual framing of sovereignty based on territorial demarcation, self-determination, and self-government is set out. Three permutations, referred to as models, of the 1648 Westphalian modern state framework are used as sovereignty reference points. A distinction is made between “internal” and “external” sovereignty. This narration leads to an observation that Modern Treaty First Nations, at best, enjoy a model-one-plus sovereignty status (similar to a municipal government). To ground the theoretical discussion, field research was undertaken with the Nisga’a First Nation of northwestern British Columbia, a Modern Treaty First Nation; the result was inconclusive. A summary observation is that First Nations must approach surplus sharing and wealth redistribution as a fluid Indigenous-values-infused policy component of their broader sovereignty vision. To bring increased rigor to their formulations, they need statistically reliable and valid assessments of the fiscal framework that underpins current First Nation-Crown relations and, at a narrow level, the impact of the Canada Revenue Agency on their sovereignty and the rights of their citizens.
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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 | 0.003 | 0.010 |
| Meta-epidemiology (narrow) | 0.000 | 0.000 |
| Meta-epidemiology (broad) | 0.000 | 0.000 |
| Bibliometrics | 0.002 | 0.004 |
| Science and technology studies | 0.010 | 0.009 |
| Scholarly communication | 0.010 | 0.003 |
| Open science | 0.002 | 0.003 |
| Research integrity | 0.001 | 0.003 |
| Insufficient payload (model declined to judge) | 0.003 | 0.000 |
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.
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".