International Taxation in Canada: Principles and Practices, 5th Edition
Bibliographic record
Abstract
"This book provides an understanding of the underlying policy governing international tax rules as well as how foreign tax laws interact with Canadian laws. In this edition, the authors are looking to make the book more accessible to students and young practitioners while aiming to make it valuable to judges and seasoned practitioners as well. This book is the starting point for students to enter the area of international taxation without being overwhelmed by its scope and complexity, and provides a useful summary for practitioners when navigating the complex rules of international taxation. What’s New: - Improves on earlier editions by shedding a brighter light on the “why” and “how” questions. - More context and explanation of historical evolution of key international tax rules and principles, as well as the major influences and constraints on Canadian International law - Most chapter significantly rewritten - New chapter dedicated exclusively to Tax Treaties - Taxation of Foreign Affiliates is now in 2 separate chapters (Chapter 15 focuses on passive income and Chapter 16 focuses on active business income and the foreign affiliate dividend regime) - Two NEW Chapters (Chapter 11 on the taxation of foreign-controlled Canadian corporations and Chapter 17 on recent international tax reforms through the BEPS projects and the future of Canadian income tax law)."-- Provided by publisher.
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 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 | 0.003 |
| Meta-epidemiology (narrow) | 0.001 | 0.001 |
| Meta-epidemiology (broad) | 0.000 | 0.000 |
| Bibliometrics | 0.004 | 0.010 |
| Science and technology studies | 0.008 | 0.004 |
| Scholarly communication | 0.010 | 0.003 |
| Open science | 0.002 | 0.002 |
| Research integrity | 0.002 | 0.002 |
| Insufficient payload (model declined to judge) | 0.030 | 0.007 |
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".