2026 Tax Conference to Explore AI’s Legal and Regulatory Impact
December 15, 2025
As a premier gathering of tax law experts, the D.C. Bar Taxation Community’s annual Tax Conference brings together a distinguished roster of speakers, including senior government figures from the IRS and the Department of the Treasury, scholars from the nation’s leading law schools, and attorneys from the top law firms.
From tax law changes stemming from the One Big Beautiful Bill Act to the taxation of cryptocurrencies and the impact of AI on tax law, the 2026 conference on January 7–8 will tackle emerging issues and provide attendees valuable insights to strengthen their practice.
Among the highly anticipated sessions is “Rise of the Machines: How Artificial Intelligence Is Changing the Tax World” on January 8, to be moderated by Professor Mindy Herzfeld of the University of Florida Levin College of Law and counsel at Potomac Law Group.
Herzfeld has been a contributing editor to Tax Notes International since 2014 . She has also written several editions of the textbook International Taxation in a Nutshell and developed a first-of-its-kind course on artificial intelligence and taxation. Below, Herzfeld talks about the challenges and opportunities for lawyers at the intersection of AI and tax law.
Who are the panelists that have been assembled to discuss AI’s impacts on tax law?
The member panelists include Stephen Bonovich, vice president of tax and trade at OpenAI. Obviously, he’s got a unique perspective … really, from two angles. He sees what’s going on in the company every day, but he also thinks about using AI tools from the perspective of an in-house tax director.
John McDonald, another panelist, is a tax practitioner and computer engineer at [PricewaterhouseCoopers] who is working on the application of technology in the tax field.
Erik Christenson is a cross-border tax practitioner at Baker McKenzie in San Francisco, whose practice involves advising on tax matters related to commercialization of data and AI — [he] has authored articles and papers on these topics.
Natalie Punchak is an attorney-advisor at the U.S. Department of the Treasury.
It is a very dynamic group of people who have been thinking about how tax law can, should, and will evolve in response to developments in the tech space.
How has AI already changed tax law?
One area involves how, on the research side, tools like LexisNexis and Westlaw require the lawyer, the practitioner, or the user to formulate a question or look for words to search for a result. Obviously, the research capabilities, the amount of data that’s out there, and the ability of an AI tool to capture what the user is trying to ask have really advanced in an extraordinary fashion.
In the six years that I have been teaching a course on AI and tax, both tax-specific and non-tax-specific research tools have been developed. There are advantages and disadvantages to each of them.
Of course, there is also document production … AI can draft documents for users. There’s the data analytics aspect, which is just extraordinary. Tax compliance and tax planning are very heavily data-driven and require systems that talk to one another, and AI can help with a lot of that.
There is also a lot of activity on the tax administration side. The OECD [Organization for Economic Cooperation and Development] just put out a report on tax authorities’ use of AI. These are just some of the primary areas in which change is taking place.
What concerns do you have with AI?
I think all practitioners [and law students] need to be mindful of both the enormous opportunities and risks that the tools present. [They must be] able to figure out how to incorporate the tools into their practice, but also learn to develop oneself and train others to utilize these tools in the right way, and in an efficient way.
AI still hallucinates and doesn’t like to say, “I don’t know,” so it can give wrong answers. An answer is only as good as the prompt someone gives the tool. Understanding that the opportunities have also come with the need to ensure that you are grounded in the risks and [have the] knowledge of how to use the tool properly is important.
I think there is, and you can already see this, a lot of pressure on service providers to incorporate AI into their offerings and to drive the price down. That seems to be a trend … that service providers, lawyers, accountants, and consultants will be thinking about their pricing and their technology use.
Are the current tax laws able to address potential issues that AI might introduce?
All the legal ethics and privacy concerns that apply to the law generally are also relevant in the tax space. As for regulations, it’s an issue worth considering from several different perspectives.
The tax rules don’t adequately address some of the changes to business practices that have been presented by digital technology, which AI use will make more acute. How to adapt these regulations — thinking about where changes are needed — is going to be a big question in the coming years.
The rules that allocate taxing rights among different jurisdictions are generally premised on the notion that it’s human work that creates value. So, the right of a country or state to tax comes from the underlying premise that a person does work, creates a valuable product or service that is sold for a profit, and that profit is taxable income for the jurisdiction that has the right to tax it.
When you reduce or remove the human element from the activity that gives rise to the profitable good or service, you raise a whole lot of questions about where the activity took place, and the question then becomes who has the right to tax it? We’ve seen some of those questions arising in the context of digital or remote sales, but as AI takes on more and more functions that have been traditionally thought of as human, these questions become more acute.
That’s one area where regulations will need to be updated. There’s a whole other area in the legislative space, which is how to incentivize AI development. What should regulators or legislators be doing to ensure that the United States is on the cutting edge of AI development? Related to that is the question of what kind of incentives or regulations are needed in the energy space because AI development is closely tied to energy and the ability to meet AI’s energy needs.
And then, if you’re talking about regulatory oversight, there are a lot of questions that arise in the government’s use of AI. Who’s watching over the government when a tax administration implements AI? Determining who to audit? … What kind of oversight is there? Is there a human oversight over these decisions? These are important questions as well.
The 10th Annual Tax Conference takes place at the D.C. Bar on January 7–8, 2026. Click here to explore the program and register.
