Our Tax Foresight analyzes the case of Johns-Manville Canada Inc. v. The Queen, where the Supreme Court of Canada set the standard for whether tangible
In Feizmohammadi v. The Queen, 2017 TCC 28 the Tax Court of Canada held that the taxpayer’s condominium sale constituted income from a business.
Struck v. The Queen, where the Tax Court of Canada held that the taxpayer’s corporation had conferred a shareholder benefit on the taxpayer by making mortgage
The Canada Revenue Agency recently confirmed their concern about non-passive investments in TFSAs—what does this mean for taxpayers?
When is a Worker an Employee for Tax Purposes? Tax Foresight reflects the newest case law and takes every case into account when providing its prediction.
Tax Foresight reflects the newest case law and takes every case into account when providing its prediction. Learn more
BMSS and Blue J partner to improve client deliverables in tax research & diagramming using advanced AI and intelligent diagram tech.
Mauldin & Jenkins partners with Blue J to create client-ready diagrams efficiently while maintaining quality standards. Discover more about this partnership
The GILTI regime, when and to whom it applies, and the general method for determining the amount of tax liability a taxpayer would incur as a result of GILTI
Discover how Blue J's machine-learning modules can help tax practitioners navigate complex federal income tax issues, as demonstrated by analysis of the Ryder
Blue J predicts with 90 percent confidence that the appeal will be dismissed on the issue of whether a partnership exists.
Tax research and analysis can be complicated. Sifting through hundreds of irrelevant cases is time-consuming and monotonous. Now that legal technology...
As the Supreme Court of the United States (the “U.S. Supreme Court” or the “Court”) pointed out in Container Corp. of Am. v. Franchise Tax Bd.,
Is an activity eligible for the Tax Credit for Increasing Research Activities (R&D Credit)? We will walk through these steps...
On May 17, 2021 the Supreme Court of the United States issued its decision in CIC Services, LLC v. Internal Revenue Service et al. Costs not tied to any tax.
§ 6015 is commonly called the “innocent spouse relief” provision. Innocent spouse relief generally relieves a spouse of all responsibility...
Blue J’s Innocent Spouse Relief will provide a prediction regarding the likelihood of spousal tax relief under IRC § 6015 or § 66(c). Blue J’s data analytics
This month’s installment evaluates the strength of the commissioner’s economic substance arguments in the pending Perrigo2 case, read more...
Comparing two recent decisions involving related parties, one with a debt outcome and the other an equity outcome, we illustrate the relative significance...
The Step Transaction Doctrine (Step Doctrine) determines whether the court should treat a series of transactions as a single taxable event for federal tax...
Thoma v. Commissioner (T.C. 2020) involves a dispute over income earned from accounting services. Tax Foresight correctly predicted three outcomes
Certain organizations are exempt from federal income tax. However, pursuant to § 511 of the Internal Revenue Code (IRC), the resulting income is nonetheless
IRC § 66722 permits the government to impose the “Trust Fund Recovery Penalty” on persons other than those employers or businesses...
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