Bibliographic record
Abstract
By broadly interpreting the general anti-avoidance rule in Part IVA of the Income Tax Assessment Act 1936, the High Court, in FCT v Spotless Services Ltd 96 ATC 5201, has exposed the inadequacies of the provision. The rejection of the "commercial transaction exception" has generated considerable uncertainty and trenchant criticism by the tax advisory profession. The provision is now unworkable. A new approach is mandated. The Review of Business Tax proposal that Part IVA be applied according to the underlying policy of the tax laws suggests the way forward. Such an approach would assimilate the Australian position with proposals considered in the United Kingdom and New Zealand and the approach achieved in Canada. However, it would involve a departure from the traditional literal approach to interpreting tax laws. Critics might question where is the protection of taxpayers that is the basis for the literal approach. This must be founded in a clear expression of objects, an independent review board and a sensible rulings, dispute resolution and penalty regime.
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 | 0.031 | 0.078 |
| Meta-epidemiology (narrow) | 0.001 | 0.001 |
| Meta-epidemiology (broad) | 0.002 | 0.001 |
| Bibliometrics | 0.004 | 0.003 |
| Science and technology studies | 0.018 | 0.068 |
| Scholarly communication | 0.030 | 0.047 |
| Open science | 0.005 | 0.014 |
| Research integrity | 0.029 | 0.040 |
| Insufficient payload (model declined to judge) | 0.011 | 0.008 |
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".