Blue J launches new section 55 solutions in collaboration with Felesky Flynn
Blue J Legal, the leading provider of analytics for tax positions, and Felesky Flynn LLP, one of Canada’s top tax law and advisory firms, announced today an innovative partnership that has led to dynamic guided analysis tools for subsection 55(2) and paragraph 55(3)(a) of the Income Tax Act ("ITA"). The tools are the latest addition to the Canadian version of Blue J Tax and are available for immediate use.
The subsection 55(2) and paragraph 55(3)(a) tools provide guidance on whether the anti-avoidance rule in subsection 55(2) of the ITA could be applicable to convert a tax-free inter-corporate dividend into proceeds of disposition or a gain from the disposition of capital property. Both tools synthesize and take into account CRA administrative guidance throughout for added utility for users. They also provide a dynamic approach to users' fact patterns and are able to respond to a particular situation with the relevant prompts to alert practitioners to potential pitfalls and to provide helpful guidance on the potential application of these complex legislative provisions.
"We're excited to provide these advanced tools for expert tax professionals on our updated Blue J Tax platform," says Benjamin Alarie, Co-founder and CEO of Blue J. "Felesky Flynn is recognized as a leading tax law firm and we are proud to have the chance to work with them. The section 55 solutions are an important step forward, and we look forward to helping streamline the analysis of these complex rules for tax professionals across Canada."
The tools announced today are unique in that they direct the user to relevant CRA interpretations and also explain what that guidance means for the user’s unique situation. The collaboration between Blue J and Felesky Flynn LLP marks the first time an advanced machine learning platform is able to provide guidance on the potential application of the anti-avoidance rule in subsection 55(2) and the potential exemption to that anti-avoidance rule in paragraph 55(3)(a).
"Combining our firm’s tax law expertise with Blue J’s leading technology allowed us to collectively develop a resource that should simplify these difficult tax areas and make them more accessible to a broader range of tax practitioners," said Brett Anderson, Co-Managing Partner of Felesky Flynn LLP. "Our teams have worked diligently over this past year to create a simple, intuitive solution that provides important guidance on the potential application of subsection 55(2) and paragraph 55(3)(a). The outcome is a pair of robust tools that the leading tax practitioners across the country can leverage to assist them in providing the highest quality tax advice to clients."
The new tools are a critical investment for Blue J as the company continues to expand its Canadian operations with new platform updates.
About Blue J
Blue J uses machine learning and artificial intelligence to make the law more transparent and accessible. The company's technology saves users hours of time and offers confident answers in challenging circumstances. While the company's initial focus is on tax and employment law, the technology is versatile and is being extended to cover other areas of law in the U.S., Canada, and around the world. For more information, visit www.bluejlegal.com.
About Felesky Flynn
With offices in Calgary, Edmonton and Saskatoon, Felesky Flynn LLP, legal counsel, provides Canadian and international tax planning and tax representation and litigation advice to clients throughout Canada and internationally. Its highly qualified lawyers focus on solving difficult problems and are committed to maximizing value for our clients. For more information, visit www.felesky.com.
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