Overview

Blue J Legal and Thomson Reuters are pleased to be in a joint initiative to bring Tax Foresight, a new suite of artificial intelligence-based tax case outcome predictors, to the Canadian market.

There are many questions in tax law where reasonable arguments can be made on both sides, and there is no way to resolve the competing considerations conclusively short of going before a judge. Tax Foresight leverages the power of machine learning and artificial intelligence to allow corporate tax professionals, tax preparers, accountants, and tax lawyers to rapidly resolve in advance how courts will rule in new tax situations, based on their unique factual scenarios.

See a full list of legal issues addressed by Tax Foresight below.

 

 

 

 

Preview the Tax Worker Classifier

 

 

The science behind Tax Foresight 

 

Tax Foresight allows you to simulate the judgment of a court in a new situation. Using advances in artificial intelligence and extensive training by computer scientists and law professors from the University of Toronto, Tax Foresight helps you to navigate the uncertainty that results from competing reasonable arguments.

Tax Foresight analyzes fact situations using deep learning, discovering in seconds hidden patterns in the case law. It provides answers, links to relevant cases, and generates tailored explanations of its analysis.

When using Tax Foresight, you can always have confidence in its conclusion, reasoning behind the result, and what to do next. 

 

A revolutionary new way to find cases

Tax Foresight empowers professionals by allowing them to find the cases they need faster than ever before. With Tax Foresight's Case Finder, there is no need to guess at keywords or boolean terms. Simply navigate all of the cases relevant to your client's legal issue using the factors that matter to your situation.

A revolutionary new way to find cases
 
 

Tax Foresight's Case Finders contain all of the case law on a particular legal issue, so you can feel confident your search contains all of the relevant information.

Legal Issues

See the ever-growing list of issues addressed by Tax Foresight, including income vs. capital, residency, and worker classifications.

Tangible Expenditure

Tangible Expenditure

Are expenditures on tangible property (e.g., land, buildings, or machinery) currently deductible expenses or capital expenditures?

Intangible Expenditure

Intangible Expenditure

Are expenditures on intangible property (e.g., customer lists or intellectual property) currently deductible expenses or capital expenditures?

Real Estate

Real Estate

Are gains or losses on the sale of real estate treated on account of income or capital?

Securities Trading

Securities Trading

Are gains or losses from securities trading treated on account of income or capital?

Worker

Worker

Is a worker an employee or independent contractor for tax purposes?

General Anti-Avoidance Rule (GAAR)

General Anti-Avoidance Rule (GAAR)

Is a transaction subject to a federal or provincial general anti-avoidance rule?

Capital Cost Allowance (CCA)

Capital Cost Allowance (CCA)

Under which class does an asset fall under pursuant to Schedule II of the Income Tax Regulations?

Assessment Period

Assessment Period

Is a misrepresentation attributable to neglect or carelessness such that the CRA may assess or reassess past the normal reassessment period under subparagraph 152(4)(a)(i) of the ITA or paragraph 298(4)(a) of the ETA?

Shareholder Benefits

Shareholder Benefits

Are benefits received as a shareholder taxable under subsection 15(1) of the ITA?

Home Office

Home Office

Are expenses related to work space in the home deductible from income for tax purposes?

Residency

Residency

Is an individual resident in Canada for tax purposes such that his or her worldwide income is taxable in Canada?

Carrying on Business

Carrying on Business

Do the operations of a non-resident enterprise constitute carrying on a business in Canada such that income from that business is taxable in Canada?

Central Management & Control

Central Management & Control

Is the central management and control of a corporation in Canada such that the corporation will be considered resident in Canada for tax purposes?

Gross Negligence

Gross Negligence

Was a taxpayer grossly negligent with respect to a false statement or omission on a tax return such that the taxpayer is subject to penalties under subsection 163(2) of the ITA?

Directors' Liability

Directors' Liability

Can a director use the due diligence defence to avoid liability for a corporation’s failure to deduct, withhold, remit, or pay amounts as required by the ITA or the ETA?

Taxable Benefits

Taxable Benefits

Is an employee benefit received in connection with employment considered to be income for the purposes of the ITA?

Business vs. Property: Rental

Business vs. Property: Rental

Is rental income received by a taxpayer from real property income from business or income from property?

Windfall

Windfall

Is a wagering activity (e.g., a card game or lottery) a business?

CCPC

CCPC

Is a corporation a Canadian-controlled private corporation for the purposes of the ITA?

T2057: Section 85 Election Eligibility

T2057: Section 85 Election Eligibility

Is a disposition of property by a taxpayer to a taxable Canadian corporation eligible for an election under section 85 of the ITA?

T2058: Section 85 Election Eligibility

Is a disposition of property by a taxpayer to a taxable Canadian corporation eligible for an election under section 85 of the ITA?

Single vs. Multiple Supply

Single vs. Multiple Supply

Does a transaction including different elements consist of a single supply or multiple supplies under the Excise Tax Act?

Interest Deductibility

Interest Deductibility

Is an income expense deductible from income for income tax purposes?

Primary Beneficiary

Primary Beneficiary

Is the primary beneficiary of an expenditure the employer or the employee?

Exempt Financial Services

Exempt Financial Services

Does an intermediary service constitute "arranging for" a financial service under subsection 123(1) "financial service" (l) of the Excise Tax Act, such that it is an exempt or zero-rated supply for GST/HST purposes?

Permanent Establishment Classifier

Permanent Establishment

Does a United States resident have a “permanent establishment” in Canada pursuant to paragraph 1 or paragraph 5 of Article V of the Canada-US Tax Treaty?

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