Rethinking the Nature of Incorporeal Properties in International Taxation – A Theory of Removable and Non-Removable Incorporeal Properties
Bibliographic record
Abstract
Globalization of trade and easy movement of money and people across borders, along with the growth of e-commerce, have created an environment where international tax avoidance (“ICTA”) and aggressive tax planning are becoming increasingly important. Over half of world trade passes through tax havens, and over 60% of international trade occurs within MNEs, making ICTA a significant source of revenue loss for governments. ICTA results from misuse of domestic and international laws to separate the earning of revenue from the liability to taxation. By abusing inconsistencies between domestic and international tax rules, MNEs are able to earn large revenues in a country without being liable to full taxation on those revenues. This is achieved by shifting income out of, and expenses into, a country. This artificial movement of money across borders can result in cases where income is earned and not taxed at all in any country.One common method of shifting income from one jurisdiction to another is through the use of incorporeal properties such as the domestic-statutorily created and protected intellectual property rights such as patents, the mixed statutory-common-law protected intellectual property rights such as copyrights and trademarks, and contractually created and protected intellectual property rights such as trade-secret. This paper attempts to draw a meaningful distinction, at least for international taxation purposes, as between these three categories of incorporeal properties by reference to current Canadian non-resident tax treatment of Taxable Canadian Property.
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How this classification was reachedexpand
Full frame distilled prediction
Teacher imitationNot 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.
Codex and Gemma teacher scores by category
| Category | Codex | Gemma |
|---|---|---|
| Metaresearch | 0.003 | 0.001 |
| Meta-epidemiology (narrow) | 0.000 | 0.000 |
| Meta-epidemiology (broad) | 0.000 | 0.000 |
| Bibliometrics | 0.000 | 0.000 |
| Science and technology studies | 0.000 | 0.000 |
| Scholarly communication | 0.000 | 0.001 |
| Open science | 0.000 | 0.000 |
| Research integrity | 0.000 | 0.001 |
| Insufficient payload (model declined to judge) | 0.000 | 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 teacher head, 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".