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Tax Foresight

AI-powered cross-border tax research and planning. 

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How Tax Foresight Works

Tax Foresight uses machine learning to predict how a court would rule in your cross-border scenario with over 90% accuracy.
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Input your scenario

Fill out a brief questionnaire with the facts of your unique tax situation.

Run the analysis
Run the analysis

Tax Foresight uses AI to compare your situation to all relevant previous cases.

Support your position
Support your position

Review prediction, a tailored explanation of the result, and a list of similar cases.

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Document and share

Download a report of Tax Foresight’s prediction and share with key stakeholders.


US tax issues covered

Nonresident Trade or Business

Is a nonresident alien individual or foreign corporation engaged in a trade or business within the United States for federal taxation purposes?

Transfer Pricing

Find cases in which transfer pricing was discussed in the context of federal income taxation.

Is an individual a U.S. resident alien for the purpose of federal income tax?
Global Intangible Low-Taxed Income (GILTI)

Is an entity subject to tax under the newly enacted Global Intangible Low-Taxed Income (GILTI) regime?

Economic Substance

Does a transaction have economic substance for tax purposes?

Debt vs. Equity

Is an interest in a corporation debt or equity for federal tax purposes?

§ 6662 Accuracy Related Penalty: Reasonable Cause and Good Faith

Can a taxpayer use the reasonable cause and good faith defense to avoid the accuracy-related penalty for an underpayment of tax pursuant to IRC § 6662?

Worker Classification

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

Trust Fund Recovery Penalty

Is a person liable to pay the Trust Fund Recovery Penalty pursuant to § 6672?

Real Estate

Is a piece of real property a “capital asset” under Section 1221(a)(1) of the IRC?

Deductible Trade or Business Expense: US Businesses

Is a trade or business expense an ordinary and necessary expense under § 162(a)?

Unrelated Business Income Tax

Is an exempt organization obligated to pay tax on income generated from an unrelated trade or business pursuant to § 511?

Worker Classification

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

Tax-Free Reorganizations: Continuity of Business Enterprise

Does a corporate reorganization meet the continuity of business enterprise requirement for a § 368 tax-free reorganization?

Research Credit Case Finder

Find cases discussing the Tax Credit for Increasing Research Activities (R&D Credit).

Research Credit Navigator: Qualified Activities

Is an activity eligible for the Tax Credit for Increasing Research Activities (R&D Credit)?


Artificial intelligence adds a dimension to your thinking. The analysis identifies insights that you might not have thought of and may lead you to a case that adds to your approach to a particular issue. That’s invaluable. 

David Chodikoff, Partner
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Employee or independent contractor? 

Preview our tax worker classifier for free to explore our platform and see a classifier in action.