International Taxation in Canada: Principles and Practices [2nd Edition]
Bibliographic record
Abstract
The second edition of International Taxation in Canada continues the journey of assisting the reader to understand Canada's international tax regime. The authors strive to do so as comprehensively as possible, without overwhelming their audience with the massive scope and complexity of the topic. The intended audience includes lawyers and law students in Canada as well as students of business, tax and accountancy.\nThe book continues to reflect the influences and experiences of the authors in teaching and practicing in the international tax area over an extended period of time. Substantively, the second edition includes updates on legislative changes and judicial decisions that are particularly helpful in illustrating how income tax principles accommodate international transactions. Tax rules have developed in the intervening years since the first edition. Some rules, in particular a proposed regime concerning foreign investment entities, have been completely abandoned. Conversely, others, such as those concerned with non-resident trusts and foreign affiliates, have been become more settled.\nNonetheless, Canada's international tax laws have become more and more complicated over time. This unique book provides an understanding of the main principles and practices that frame international tax rules, which will assist you when confronted with the seemingly endless tax complexities of cross-border transactions, along with an appreciation of how foreign tax laws interact with their Canadian counterparts.
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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 | 0.001 | 0.002 |
| Meta-epidemiology (narrow) | 0.001 | 0.001 |
| Meta-epidemiology (broad) | 0.000 | 0.000 |
| Bibliometrics | 0.004 | 0.011 |
| Science and technology studies | 0.008 | 0.003 |
| Scholarly communication | 0.010 | 0.002 |
| Open science | 0.002 | 0.002 |
| Research integrity | 0.002 | 0.002 |
| Insufficient payload (model declined to judge) | 0.024 | 0.006 |
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".