2026 Tax Law Trends: Shifting Legislation, Administration and Technology

Tax practitioners are confronting a convergence of forces that will shape tax planning, compliance and controversy for years to come. Tax trends in 2026 include advances in artificial intelligence, the implementation of major new legislation, evolving international tax frameworks and a rapidly changing administrative law environment are all redefining how tax professionals operate within the system. 

An ongoing trend for 2026 is the implementation of the One Big Beautiful Bill Act (OBBBA). Enacted in 2025, OBBBA is a major tax industry update and one of the most significant pieces of tax legislation in recent years. OBBBA changes span multiple sectors and, while it established broad policy changes, much of its impact will depend on the guidance issued by the Treasury Department and the Internal Revenue Service (IRS).

“Over the coming months, tax practitioners will continue to interpret proposed and final regulations, revenue procedures, notices and other guidance aimed at clarifying how OBBBA’s provisions apply in practice,” said Stephen Olsen, professor of practice and faculty director of Villanova University’s Graduate Tax Program. “Similar to prior major tax legislation, questions around effective dates, transitional rules, elections and coordination with existing provisions will be front and center.” 

This period of interpretation creates both risk and opportunity, but tax practitioners who engage early and proactively with the evolving rules may be better positioned to take advantage of extensions, incentives or structural changes introduced by OBBBA. 

Recent Supreme Court decisions are also reshaping the tax landscape in ways that will become more apparent in 2026. Over the past few years, the Court issued a series of rulings affecting both tax law specifically and administrative law more broadly, with implications that extend beyond any single case. 

One of the most consequential developments is the Court’s decision in Loper Bright Enterprises v. Raimondo, which overruled the 40-year-old Chevron doctrine. Under Chevron, courts generally deferred to reasonable agency interpretations of ambiguous statutes. With that now eliminated, power has shifted back to judges to interpret statutes, and taxpayers and practitioners can expect increased judicial scrutiny of Treasury regulations and other administrative guidance. In 2026, this is likely to lead to more challenges to the validity of regulations, especially in areas where statutory authority is unclear or guidance is perceived as overreaching.

In SEC v. Jarkesy the Supreme Court’s decision was based on the Seventh Amendment, which guarantees the right to a jury trial for “Suits at common law.” The Court ruled that when the Securities and Exchange Commission (SEC) seeks civil monetary penalties for fraud, defendants have a constitutional right to a jury trial in federal court. This decision struck down the SEC's practice of using its own administrative tribunals to bypass juries. This ruling opened the door to broader constitutional challenges in enforcement actions, including in the tax context. Questions surrounding the availability of jury trials under the Seventh Amendment and the validity of administrative penalties remain. 

“Together, these cases were sea changes in how the IRS operates, what regulations are valid and how they can impose penalties,” said Olsen. “They are setting the basis for ongoing challenges before the courts, and we anticipate long-term consequences for tax administration, enforcement and dispute resolution.”

International tax is another area of significant evolution. In early 2026, the Organization for Economic Cooperation and Development (OECD), an international organization with 38 member countries that promotes policies to improve economic growth and world trade, announced a new “side-by-side” framework designed to address concerns raised by U.S.-based multinational companies regarding compliance with OECD’s Pillar Two global minimum tax. The framework introduces new safe harbor rules that allow certain U.S. companies to be compliant with Pillar Two while remaining subject primarily to the U.S. tax system. 

For many U.S.-based multinationals, this development offers relief from uncertainty and the risk of overlapping or inconsistent tax obligations across jurisdictions. However, the side-by-side framework is not without its complexities. Questions remain regarding eligibility, documentation requirements, coordination with local country rules and how the framework will be applied in practice.

“Tax professionals will need to closely monitor how the side-by-side rules are interpreted and enforced, and how they interact with existing U.S. international tax provisions,” said Olsen. “These developments will also influence how international tax is taught to tax students in programs like Villanova Grad Tax’s International Tax Certificate. This is an area we will cover extensively with our students.”

Like many industries, Artificial intelligence (AI) is no longer viewed as an experimental tool in tax, but rather a core component of how firms operate. Tax practitioners are increasingly leveraging AI to automate routine and time-intensive tasks such as document review, data input and extraction and research. AI tools offer increased efficiency, reduced error rates and the ability for tax professionals to spend more time on higher-value advisory work.

“AI is quickly taking root in the tax industry,” said Olsen. “However, the growing integration of AI also highlights the continued importance of technical expertise. AI won’t replace tax practitioners. The tools are only as effective as the inputs and oversight provided by skilled tax professionals.”

As firms adopt AI-driven solutions, they must remain vigilant about accuracy, bias, data security and compliance with professional standards. AI capabilities must be combined with strong technical judgment, robust review processes and clear governance around how these tools are used.

The remainder of 2026 will be a pivotal year for the tax profession. Success in the tax field depends on practitioners’ adaptability, technical depth and a willingness to engage with emerging trends in tax. To keep up with the latest trends and have a competitive advantage over peers, it has never been more important for practitioners to further their education and hone their skills. 

At Villanova, the Master of Laws in Taxation (LLM) for lawyers and the Master of Taxation (MT) for accounting and business professionals, are two rigorous graduate tax degree programs that educate students on the legal regulations and accounting principles that affect the ever-changing tax landscape. Also, for qualified tax professionals who want to expand their skills in a specific area, certificates in International Tax, Employee Benefits, Estate Planning and State and Local Tax (SALT), can be completed as stand-alone credentials or in conjunction with the LLM and the MT. 

For tax practitioners, 2026 is not just about keeping up — it is about rethinking how tax work is done and how value is delivered in an increasingly interconnected and technologically driven world.