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Blue J Tax

Analytics for tax positions.  

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How Blue J Tax Works

Blue J Tax uses machine learning to predict your cross-border scenario with over 90% accuracy.
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Fill out a brief questionnaire with the facts of your unique tax situation.

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Run the analysis

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

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Fortify your position

Simulate the effect of different facts on the outcome and review a list of similar cases.

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US tax issues covered

Debt vs. Equity

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

Transfer Pricing

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

Base Erosion and Anti-Abuse Tax (BEAT)

Is an entity subject to tax under the newly enacted Base Erosion and Anti-Abuse Tax (BEAT) regime?

Global Intangible Low-Taxed Income (GILTI)

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

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?

Is an individual a U.S. resident alien for the purpose of federal income tax?
Economic Substance

Does a transaction have economic substance for 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?

Deductibility of Trade or Business Expenses

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?

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)?

All-Events Test: Expenses

Has an expense accrued by a given tax year?

All-Events Test: Economic Performance

Has economic performance occurred in a given tax year as required by the all-events test?

CFC and PFIC Rules

Is a corporation a controlled foreign corporation or a passive investment foreign company for the purposes of the Internal Revenue Code?

Step Transaction Doctrine

Should multiple transactions be treated as a single taxable event?

All-Events Test: Income

Has an item of income accrued by a given tax year?

Insurance Arrangement

Does an arrangement between parties constitute insurance for federal taxation purposes?

De Facto Partnerships
Does an arrangement between parties constitute a “partnership-in-fact” for federal tax purposes?
Innocent Spouse Relief

Can a person obtain tax relief as an "innocent spouse?"

Constructive Receipt of Income

Does a taxpayer have constructive receipt of income in the relevant tax year for federal taxation purposes?

Assignment of Income - Income from Assets or Business

Is asset or business-derived income taxable to the transferor or transferee after assignment, pursuant to the assignment of income doctrine?

Assignment of Income - Income from Services

Is income earned by the transferor’s services taxable to the transferor or transferee after assignment, pursuant to the assignment of income doctrine?


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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