scholarly journals Ahead by a Century: Tim Edgar, Machine-Learning, and the Future of Anti-Avoidance

2020 ◽  
Vol 68 (2) ◽  
pp. 613-629
Author(s):  
Benjamin Alarie
Keyword(s):  
Machine Learning ◽  
Complete System ◽  
Tax Avoidance ◽  
Tax Law ◽  
Legal Development ◽  
The Future ◽  
Avoidance Measures ◽  
Tax Systems ◽  
The Law ◽  
Current Stage

Tim Edgar's contributions to our understanding of tax avoidance and anti-avoidance remain ahead of their time. In this paper, the author argues that Edgar's work on building better general anti-avoidance rules (GAARs) was particularly prescient—correct in its claim that tax avoidance can and should be eliminated through effective anti-avoidance measures. The author maintains that although Edgar's position and vision will eventually be realized, Edgar himself did not anticipate the manner in which this would occur. The author's first claim is that the law is incomplete, and this incompleteness problematizes any insistence on the immediate adoption of strict anti-avoidance measures. The author explains how and why the current stage of legal development falls significantly short of completely specifying the law, including the tax law. The author's second claim is that the next decades will bring considerably more sophisticated and effective approaches to legal development. Described, in broad terms, are some of the mechanisms through which our tax systems are moving toward a legal singularity (a state of the law that is functionally complete and well specified). The author proceeds to outline the implications of his two main claims for the future of GAARs and anti-avoidance—specifically, how the realization of a much more complete system of law will leave effectively no further scope for tax avoidance. Tax law, in the asymptotic realization of Edgar's work and vision, will become well targeted and well equipped to address tax avoidance. Tax avoidance as we know it will cease to exist.

THE SHIFTING SANDS OF UK TAX LAW

2017 ◽  
Vol 76 (3) ◽  
pp. 502-506
Author(s):  
Guy Mulley
Keyword(s):  
Supreme Court ◽  
Tax Avoidance ◽  
Tax Law ◽  
The Supreme Court ◽  
The Law ◽  
The Right

When the law is confusing, when the efforts of HM Revenue & Customs (“HMRC”) seem ineffective and when an impecunious state needs higher tax yields, what better time could there be for the Supreme Court to invoke the populist battle cry “tax avoidance” and to head for the “right” decision? Perhaps, it is respectfully suggested, when the (reasoning) means can justify the (judgmental) ends.

scholarly journals Clinical applications of artificial intelligence and machine learning in cancer diagnosis: looking into the future

2021 ◽  
Vol 21 (1) ◽  
Author(s):  
Muhammad Javed Iqbal ◽  
Zeeshan Javed ◽  
Haleema Sadia ◽  
Ijaz A. Qureshi ◽  
Asma Irshad ◽  
...  
Keyword(s):  
Artificial Intelligence ◽  
Machine Learning ◽  
Cancer Diagnosis ◽  
Disease Risk ◽  
Clinical Applications ◽  
Optimal Decision ◽  
Great Promise ◽  
Time Range ◽  
Base System ◽  
The Future

AbstractArtificial intelligence (AI) is the use of mathematical algorithms to mimic human cognitive abilities and to address difficult healthcare challenges including complex biological abnormalities like cancer. The exponential growth of AI in the last decade is evidenced to be the potential platform for optimal decision-making by super-intelligence, where the human mind is limited to process huge data in a narrow time range. Cancer is a complex and multifaced disorder with thousands of genetic and epigenetic variations. AI-based algorithms hold great promise to pave the way to identify these genetic mutations and aberrant protein interactions at a very early stage. Modern biomedical research is also focused to bring AI technology to the clinics safely and ethically. AI-based assistance to pathologists and physicians could be the great leap forward towards prediction for disease risk, diagnosis, prognosis, and treatments. Clinical applications of AI and Machine Learning (ML) in cancer diagnosis and treatment are the future of medical guidance towards faster mapping of a new treatment for every individual. By using AI base system approach, researchers can collaborate in real-time and share knowledge digitally to potentially heal millions. In this review, we focused to present game-changing technology of the future in clinics, by connecting biology with Artificial Intelligence and explain how AI-based assistance help oncologist for precise treatment.

The Accrual Accounting Principle and its Implications for Portuguese Tax Courts Decisions

2020 ◽  
Vol 0 (0) ◽  
Author(s):  
Daniel Taborda ◽  
João Sousa
Keyword(s):  
Tax Avoidance ◽  
Case Law ◽  
Tax Law ◽  
Income Transfer ◽  
Legal Decisions ◽  
Taxable Income ◽  
Principle Of Justice ◽  
Legal Arguments ◽  
Accounting Principle ◽  
Flexible Application

AbstractTo the best of our knowledge, this is the first paper focusing on the interpretations issued by different Portuguese courts concerning the application of the accrual principle established in the Corporate Income Tax Code.This paper uses a database of the Portuguese tax courts’ decisions and employs a case law-based research methodology to address the following question: under which circumstances the principle of justice may affect the strict application of the accrual principle? After collecting twenty-four legal decisions related to the application of the accrual principle outlined in tax law, this paper summarises eleven, grouping them according to the different issues under dispute. This analysis also includes the confrontation of the assumptions used by the tax authority and the claims of the taxpayers, identifying and discussing the legal arguments to override the strict application of the accrual principle.The main conclusion is that Portuguese courts may summon the principle of justice in taxation when taxpayers violate the accrual principle, in order to prevent unfair corrections to taxable income performed in tax audits. This paper found that the tax authority typically demands a rigid use of the accrual principle while the taxpayers often argue for a more flexible application. This last perspective has been adopted by the tax courts in certain circumstances, in particular when taxable income transfer was not motivated by tax avoidance.

scholarly journals Integrating machine learning and blockchain to develop a system to veto the forgeries and provide efficient results in education sector

2021 ◽  
Vol 4 (1) ◽  
Author(s):  
Dhruvil Shah ◽  
Devarsh Patel ◽  
Jainish Adesara ◽  
Pruthvi Hingu ◽  
Manan Shah
Keyword(s):  
Machine Learning ◽  
Education Sector ◽  
Student Records ◽  
Job Roles ◽  
Student Data ◽  
Disruptive Technologies ◽  
Valid Data ◽  
The Future ◽  
Student Achievements ◽  
The University

AbstractAlthough the education sector is improving more quickly than ever with the help of advancing technologies, there are still many areas yet to be discovered, and there will always be room for further enhancements. Two of the most disruptive technologies, machine learning (ML) and blockchain, have helped replace conventional approaches used in the education sector with highly technical and effective methods. In this study, a system is proposed that combines these two radiant technologies and helps resolve problems such as forgeries of educational records and fake degrees. The idea here is that if these technologies can be merged and a system can be developed that uses blockchain to store student data and ML to accurately predict the future job roles for students after graduation, the problems of further counterfeiting and insecurity in the student achievements can be avoided. Further, ML models will be used to train and predict valid data. This system will provide the university with an official decentralized database of student records who have graduated from there. In addition, this system provides employers with a platform where the educational records of the employees can be verified. Students can share their educational information in their e-portfolios on platforms such as LinkedIn, which is a platform for managing professional profiles. This allows students, companies, and other industries to find approval for student data more easily.

Can machine learning be used to forecast the future uncertainty of military teams?

2021 ◽  
pp. 154851292199911
Author(s):  
Ronald H Stevens ◽  
Trysha L Galloway
Keyword(s):  
Machine Learning ◽  
Sensory Information ◽  
Fundamental Property ◽  
Transition Matrices ◽  
Team Members ◽  
Student Teams ◽  
The Future ◽  
Network States ◽  
Uncertainty Models ◽  
Military Teams

Uncertainty is a fundamental property of neural computation that becomes amplified when sensory information does not match a person’s expectations of the world. Uncertainty and hesitation are often early indicators of potential disruption, and the ability to rapidly measure uncertainty would have implications for future educational and training efforts by targeting reflective discussions about past actions, supporting in-progress corrections, and generating forecasts about future disruptions. An approach is described combining neurodynamics and machine learning to provide quantitative measures of uncertainty. Models of neurodynamic information derived from electroencephalogram (EEG) brainwaves have provided detailed neurodynamic histories of US Navy submarine navigation team members. Persistent periods (25–30 s) of neurodynamic information were seen as discrete peaks when establishing the submarine’s position and were identified as periods of uncertainty by an artificial intelligence (AI) system previously trained to recognize the frequency, magnitude, and duration of different patterns of uncertainty in healthcare and student teams. Transition matrices of neural network states closely predicted the future uncertainty of the navigation team during the three minutes prior to a grounding event. These studies suggest that the dynamics of uncertainty may have common characteristics across teams and tasks and that forecasts of their short-term evolution can be estimated.

The Trial of the Future: Challenge to the Law

1963 ◽  
Vol 77 (2) ◽  
pp. 393
Author(s):  
Walter V. Schaefer ◽  
Bernard Botein ◽  
Murray Gordon
Keyword(s):  
Future Challenge ◽  
The Future ◽  
The Law

scholarly journals Love in the time of Covid-19: a case-study of the complex laws governing weddings

Legal Studies ◽  
2021 ◽  
pp. 1-17
Author(s):  
Rebecca Probert ◽  
Stephanie Pywell
Keyword(s):  
First Century ◽  
Marriage Law ◽  
England And Wales ◽  
General Law ◽  
The Social ◽  
The Future ◽  
Fit For Purpose ◽  
The Law ◽  
The Impact

Abstract During 2020, weddings were profoundly affected by the Covid-19 pandemic. During periods of lockdown few weddings could take place, and even afterwards restrictions on how they could be celebrated remained. To investigate the impact of such restrictions, we carried out a survey of those whose plans to marry in England and Wales had been affected by Covid-19. The 1,449 responses we received illustrated that the ease and speed with which couples had been able to marry, and sometimes whether they had been able to marry at all, had depended not merely on the national restrictions in place but on their chosen route into marriage. This highlights the complexity and antiquity of marriage law and reinforces the need for reform. The restrictions on weddings taking place also revealed the extent to which couples valued getting married as opposed to having a wedding. Understanding both the social and the legal dimension of weddings is important in informing recommendations as to how the law should be changed in the future, not merely to deal with similar crises but also to ensure that the general law is fit for purpose in the twenty-first century.

The Conseil Constitutionnel and Judicial Review

1991 ◽  
Vol 12 (x) ◽  
pp. 61-82
Author(s):  
Richard Cicchillo
Keyword(s):  
Judicial Review ◽  
Ancien Regime ◽  
Similar System ◽  
Modern France ◽  
The Future ◽  
The Law ◽  
Ancien Régime ◽  
The Revolution

For Americans, long accustomed to judicial review of the law, the traditional absence of a similar system of constitutional control in France comes as a surprise. Closer examination however, reveals that the French politico-historico-judicial tradition inherited from the Ancien Régime and the Revolution of 1789 is deeply opposed to the development of "government by the judges." Why did the Revolution react against the judiciary? How has the idea of constitutional control evolved in modern France? What are the possible sources of legitimacy for an institution (the Conseil constitutionnel) and a concept (judicial review) cut off from the sanction of tradition? What is the future of the Conseil?

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