Audit-defensible tax guidance grounded in the IRC, CRA Act, and Canada–U.S. Tax Treaty — for founders, corporations, and cross-border entities operating in New York and Ontario.
ClearTax AI combines CPA-level depth with real-time reasoning across every area that matters to modern founders and enterprises.
LLC vs. S-Corp vs. C-Corp analysis, salary-vs-distribution optimization, and QBI deduction strategies. Real numbers, real elections.
IRC §199A · §1361 · §11Staking income, DeFi yield, NFT sales, hard forks, airdrops — capital vs. ordinary income analysis with defensible basis tracking methods.
IRS Notice 2014-21 · Rev. Rul. 2019-24Ontario/NY entity structures, FBAR compliance, Form T1135, W-8BEN-E, Closer Connection exceptions, and treaty benefit elections.
IRC §7701 · Canada–U.S. Treaty Art. IVRoyalty vs. service income classification for AI-generated revenue, passive activity rules, and software IP structuring under domestic and Canadian regimes.
IRC §469 · §861 · ITA §13Contemporaneous documentation strategy, IRS audit risk scoring, penalty abatement arguments, and Form 8886 reportable transaction analysis.
IRC §6662 · Treas. Reg. §1.6664-4QSBS exclusion eligibility, §1202 planning, deferred compensation, carried interest, and exit strategy tax minimization at Section 1045 rollover.
IRC §1202 · §83(b) · §409AEvery response follows a rigorous structure: Summary → Analysis → Legal Basis → Risk Level → Optimization. No guessing. No generics.
Describe your entity structure, jurisdiction, income type, and specific tax question in plain language.
ClearTax AI cross-references IRC sections, Treasury Regulations, CRA guidance, and treaty provisions simultaneously.
Receive a structured response: Summary, Detailed Analysis, Legal Basis, Risk Level (Low/Moderate/High), and Optimization opportunities.
Every analysis cites the exact code sections, reg paragraphs, and IRS guidance needed to defend a filing position under examination.
ClearGlass operates at the intersection of Canadian and U.S. tax law — the most complex bilateral tax relationship in the world, with $900B+ in annual cross-border trade.
From IRC §482 transfer pricing to New York's separate-entity unitary filing, ClearTax AI handles federal + state + NYC combined reporting.
From SR&ED credits to Ontario's small business deduction, ClearTax AI covers the full ITA alongside CRA interpretation bulletins.
ClearTax AI interprets all 30 articles of the Fifth Protocol Canada–U.S. Convention to minimize withholding, eliminate double taxation, and structure cross-border entities correctly from day one.
Dual-residency tiebreaker rules — permanent home, habitual abode, centre of vital interests
Business profits attribution — permanent establishment thresholds and nexus analysis
Withholding on interest — reduced to 0% between related parties under Fifth Protocol
Capital gains — exclusion for gains on shares of companies whose value derives from Canadian real property
Pensions — cross-border RRSP/IRA recognition, TFSA treatment, and §402 rollover eligibility
Mutual collection assistance — IRS and CRA share collection authority for cross-border liabilities
ClearTax AI covers the full spectrum of modern tax complexity — from DeFi protocols to international holding structures.
Staking, yield farming, NFT drops, wrapped tokens, DAO distributions, and FIFO/HIFO/Spec ID lot selection strategies.
IP royalty structuring, software licensing vs. service treatment, automated business passive activity classifications.
Delaware C-Corp, Ontario Corporation, LLC, ULC, holding company layering, and check-the-box election strategy.
GILTI, Subpart F, CFC rules, transfer pricing, BEAT, FDII, and OECD BEPS compliance for global operations.
QSBS §1202 planning, §83(b) elections, carried interest, waterfall modeling, and secondary transaction structuring.
IRS correspondence audit responses, substantial authority analysis, reasonable cause penalty defenses, and Appeals strategy.
ClearTax AI never responds with generic advice. Each analysis follows a six-section format designed to withstand IRS examination.
IRC §199A, Treas. Reg. §1.199A-1, Rev. Rul. 2023-14, relevant case law, and treaty articles — everything a tax attorney needs to draft a memorandum.ClearTax AI provides legally-grounded analysis for educational and planning purposes. It is not a substitute for advice from a licensed CPA, tax attorney, or enrolled agent. Tax law changes frequently — always verify current code sections and consult a qualified professional before filing or taking a tax position. ClearGlass Inc. does not establish an attorney-client or CPA-client relationship through ClearTax AI outputs.
ClearTax AI is now in private beta for ClearGlass clients, Ontario–NY founders, and enterprise tax teams. Request early access or reach out to discuss your specific cross-border situation.