Is a worker an employee or an independent contractor for tax purposes? Learn about employee and worker classifications with Tax Foresight.
Is a misrepresentation attributable to neglect or carelessness such that the CRA may assess or reassess past the normal reassessment period?
Jenna Schwartz, Senior Manager at Richter, explains how AI-based technologies such as Blue J Tax are helping fortify Richter’s position as a leading
David Chodikoff, a tax litigation lawyer and partner at Miller Thomson, shares how adopting new legal technologies like Blue J Legal’s AI-powered Blue J Tax,
Our system isn’t meant to provide legal advice, but rather it’s a legal research tool,” says Brudner. “We’re essentially providing the best legal information to professionals so that they can provide the best advice to their clients.
VisiCalc, developed by Harvard business student Dan Bricklin, was the first affordable and interactive electronic spreadsheet.
Blue J Tax assesses gains on the sale of two condos purchased pre construction and sold within one month of closing in DaCosta v. The Queen (DaCosta), engaging both the Real Estate and Gross Negligence Predictors.
GAAR applicable: we summarizes Birchcliff Energy Ltd. v. The Queen (TCC), 2017 TCC 234 and draws insights from Tax Foresight's GAAR Case Finder.
What is the standard for determining when a Canadian citizen is non-resident for tax purposes?
Tax Foresight's products cover various topics in tax law, including income vs. capital, sources of income, inclusions, deductions, indirect tax, jurisdiction, penalties, and elections, with new areas being added every month.
Our Tax Foresight analyzes the judgment in Bradshaw v. The Queen, where the court considered whether the taxpayer was grossly negligent under section 163(2)
On April 24, 2017, the Tax Court of Canada rendered its judgment in Armour Group Ltd. v. The Queen. Our Tax Foresight analysis of the case follows.
Maya Forestales S.A. v. The Queen, 2005 TCC 66, the Tax Court of Canada analyzed whether a non-resident corporation was carrying on business in Canada
Tax Foresight's Directors’ Liability Classifier assesses a director’s liability by evaluating whether the due diligence defence is available
When are gains from trading in securities taxable as business income? Blue J Tax predicted the outcome in Foote v. The Queen, 2017 with 95% confidence.
Blue J Predictor. This primer discusses how to determine whether real property may be considered a capital asset for federal tax purposes...
An overview of debt vs equity in a tax planning context. What factors need to be considered and how can you optimize the outcomes for your clients?
A guide to determining U.S. residency for clients, as there may be significant tax implications if they are found to be a resident alien. learn more
A guide on applying economic substance, an anti-abuse doctrine that analyzes suspect business transactions for a motive other than the obtaining of a tax...
Tax practitioners are often tasked with answering the threshold question of whether their foreign clients have carried on “a trade or business within the U.S.”
Determining the deductibility of a trade or business expense has consistently remained one of the top ten most litigated issues before the U.S. Tax Courts
the Internal Revenue Code (IRC) provides that certain sales or exchanges are not federally taxable events. One example is a § 368 corporate reorganization.
§ 6662 of the IRC imposes an ARP on persons who have underpaid their income tax as a result of certain enumerated circumstances including, but not limited to...
This month’s installment examines The Tax Court’s decision in Reserve Mechanical and the strength of its appeal on the issue. section 501(c)(15).
The R&D credit is a valuable tax incentive, and businesses want to do whatever they can to increase their chances of qualifying for it.
How machine learning predicts court decisions in tax law cases with 90% accuracy, focusing on §6672 of the Internal Revenue Code. The algorithm analyzes...
U.S. residents are now required to report income earned by controlled foreign corporations, subject to various exclusions, including newly-enacted GILTI.
The accuracy-related penalty is likely to remain the most-litigated federal tax issue in light of the TCJA's recent changes to the IRC...
Economic substance remains a frequently litigated, complex issue. Machine learning can provide unparalleled insights and clarity into the law.
23% of large law firms surveyed in a recent report by Thomson Reuters said that they had lost expected client business to one of the Big Four.
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