Two takeaways on determining whether parties are dealing at arm’s length (Damis Properties Inc. v. The Queen).
On June 7, 2021 the Ontario Superior Court of Justice released its second decision in a matter of months interpreting Ontario Regulation 228/20
The Canada Revenue Agency (CRA) has indicated that it will not be extending its guidance concerning the impact of travel restrictions on corporate residency determinations. In 2020, the CRA issued guidance concerning international income tax issues in light of COVID-19 travel restrictions. The guidance indicated that, as of March 16, 2020, when determining cases of potential dual corporate residency, the CRA will not consider a corporation to have its place of effective management in Canada solely for the reason that a director of a corporation must participate in board meetings from Canada because of travel restrictions.
The grim one year anniversary of the COVID-19 pandemic in Canada has highlighted that many businesses across the country continue to struggle financially. Two Federal assistance programs, the Canada Emergency Wage Subsidy (CEWS) and the Canada Emergency Rent Subsidy (CERS) have helped by giving out a combined total of over $77 billion in subsidies, but it is not enough for many small and medium-sized businesses.
Through a rigorous, human-driven research and development process, Blue J Legal is able to use the power of machine learning in order to synthesize the multitude of factors present in every case to make accurate predictions. Data scientists and experienced lawyers are involved at each step of the multi-faceted and laborious process, wherein we translate the universe of unstructured data, such as relevant cases and tribunal decisions, into structured data that is capable of being used in machine learning.
"Blue J’s long-term vision imagines a world in which, thanks to advances in artificial intelligence and machine learning technology, legal uncertainty is a thing of the past. Recognizing that we must hold ourselves accountable to stay true to our mission and, in so doing, avoid creating unintended outcomes, Blue J’s internal ethics committee RELAI (which stands for Responsible, Ethical, Legal AI) was founded in 2019. Our first task was to draft a Charter on Algorithmic Responsibility."
Today, Blue J, the leading provider of analytics for tax positions, and Gowling WLG, a leading international law firm, announced a new collaboration that has led to an advanced search tool for worldwide legal resources related to the interpretation of “principal purpose” in domestic legislation and treaties. The tool is the latest addition to the Canadian version of Blue J Tax and is available for immediate use by subscribers to the platform across the country.
Following more than a month of mandated province-wide shutdowns to help stop the spread of COVID-19, the Ontario government announced that a phased reopening is set to begin on Wednesday, February 10th. However, much of the province will still remain in lockdown until further notice. Small businesses are particularly affected by the closures during the pandemic.
In December the CRA announced new guidance for employees deducting home office expenses. These changes are likely to be welcomed by thousands of Canadian workers who suddenly find themselves commuting to their kitchen tables. However, certain workers are not able to take advantage of the new procedure, either because they worked from home before the pandemic, or because they do not meet a threshold of working from home at least 50% of the time over a 4-week period.
A commonly-held view among employment lawyers is that reasonable notice periods increase with the age of the employee. Is this always true? We looked at data from nearly 1,800 reasonable notice decisions by courts and tribunals across Canada since 1997.
Blue J, the leading provider of analytics for tax positions, and Osler, Hoskin & Harcourt LLP, a leader in Canadian business law, announced an collaboration
Blue J, the leading provider of analytics for tax positions, and Osler, Hoskin & Harcourt LLP, a leader in Canadian business law, announced today an innovative collaboration that has led to an advanced search tool for resources related to international transfer pricing. The tool is the latest addition to the Canadian version of Blue J Tax and is available for immediate use by subscribers to the platform across the country.
Simplex Legal is an in-house counsel boutique law firm built on a commitment to significantly reduce client legal fees while delivering the highest quality advice. Learn how they leverage Blue J L&E to provide the best service.
The complexity and novelty of the TOSI, in combination with its tax consequences affecting a wide range of private business structures, present several challenges for tax professionals.
This month in our Blue J Predicts column we examine the deduction of legal and litigation expenses in the context of the generic drug industry.
Drive efficiency with Blue J's Quick Start templates for structure chart diagramming. Pre-built for easy customization by practitioners. Save 49 hours a month
7 tax leaders share how they boost their team's efficiency with the right tools - cutting down on non-billable work and turnaround times.
Get started with this Type B Reorganization guide and a Rev. Rul. 79-4 diagram example. Find helpful examples and tips with this downloadable PDF.
We compare Excel and Blue J Diagramming to see which diagramming solution is the best for accountants and lawyers today...
Get started with this Double Dummy Structure guide. We reference IRC § 368(c), IRC § 351 and other relevant Code provisions
Get started with Type A reorganizations using this guide. Includes Type A reorganization structure examples and tips...
To better understand cases around financial recordkeeping, we use the Blue J Predictor to examine the recent Tax Court decision in Skolnick.
We compare PowerPoint and Blue J Diagramming to see which diagramming solution is the best for CPAs, M&As, and other tax practitioners.
GS2Law has chosen Blue J as the tool to support its growing tax practice. GS2Law partner, Yosef Shwedel shares why in this blog
Collaborate on diagrams and tax research with Blue J Tax. Share your work, request reviews, and allow others to edit - in one platform.
See this example of a Type C Reorganization Diagram, along with a pertinent Revenue Ruling and Rev. Rul. 67-274 that you can download as a PDF.
Using the Blue J Predictor, we analyze the judgment of the Tenth Circuit in Reserve Mechanical,1 which addressed whether a microcaptive insurance arrangement..
Elevate your tax practice with the right tools. Here are 7 helpful tools for tax practitioners that you should add to your techstack!
Download the Tax Advisory Industry Report 2022 to learn about the key challenges, goals, and opportunities for growth for tax practices today.
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