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
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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