Bloomberg Tax Insights & Commentary is featuring a recurring questionnaire of prominent tax professionals who are willing to share their thoughts about their work and the practice of tax these days. Today we feature Martin Fiore, EY Americas vice-chair of tax.
What is the biggest challenge that tax practitioners are facing in 2026?
It’s the speed of change and the pressure that comes with it. That is, striking the right balance between agility and stability in addressing today’s needs while also getting on top of what’s next.
Tax professionals today are being asked to deliver high-quality, precise results while navigating constant regulatory, technological, and business disruption. The pace is faster than it has ever been. But what has changed most is the profile of the role, not the complexity itself.
Today’s tax practitioner increasingly is expected to combine deep technical judgment with strong data literacy, technology fluency, strategic thinking, and the ability to translate insights for the business. That combination isn’t easy to develop or sustain, but the role is broader now, and professionals have to be smarter and more adaptive.
In this environment, success is less about reacting quickly and more about being structurally prepared. Teams that build readiness across talent, technology, and data are far better positioned to keep pace and to provide the kind of forward-looking insight the business now expects from tax—guidance for what works, what’s risky, and what’s next.
What tax issue keeps you up at night?
Minimum tax data requirements under Pillar Two of the global anti-base erosion rules are a significant concern because of what they demand operationally. Many organizations aren’t fully prepared for the level of data complexity created by the requirement to calculate effective tax rates at the legal entity level across every jurisdiction.
The challenge is more about data availability, quality, and consistency and less about interpretation. This is a clear example of where tax, finance, and technology need to work together in new ways.
I’m also watching how transfer pricing decisions are evolving in a Pillar Two environment. As the 15% minimum tax influences pricing decisions in one jurisdiction, those decisions can cascade, creating unintended consequences across supply chains and intercompany arrangements. That dynamic adds another layer of complexity, requiring companies to think more holistically about pricing, tax policy, and contractual commitments. While side-by-side systems may help reduce exposure, the landscape is still increasingly complex for multinational companies.
What is the biggest lesson you learned in your early years of practice?
On big decisions, it’s critical to seek input from a wide range of people at different levels within your organization.
Early in my career with EY, I learned that strong outcomes rarely come from working in isolation. In one of my first new business experiences, it quickly became apparent that the best solutions emerge through teaming, listening, and being open to perspectives that challenge your own assumptions. We all counted on each other to bring the best thinking and skills from across a wide variety of disciplines. It was inspiring to see the group come together as one team across different areas of expertise and levels of experience all doing their part, sharing ideas, and brainstorming solutions. That collaboration made the difference, and we won the engagement.
That mindset has stayed with me, and so has our practice’s commitment to an apprenticeship model for rising professionals. Success in tax, and in leadership more broadly, depends on continuous learning, resilience in the face of change, collaboration, and a genuine commitment to help others succeed alongside you.
What is the one code section you would like to change?
I would add a tax deduction for renters that mirrors the mortgage interest deduction available to homeowners. Conceptually, it would function in a similar way, providing a deduction tied to a core housing cost, but applied to rent rather than mortgage interest.
Housing is a fundamental expense, and a renter-focused deduction could help modernize the tax code in a way that better aligns with today’s economic realities, without favoring one form of housing over another. Structurally, it could sit alongside existing individual deductions, maintaining consistency in how housing-related benefits are treated.
What is the last thing you believed beyond a reasonable doubt?
That the only sure things in life are death and taxes.
To that I would now add that the pace of change in the tax profession will continue to accelerate. Technology and AI are reshaping how tax professionals analyze data, manage risk, and deliver insight, and expectations are evolving alongside that.
At the same time, I also strongly believe that some fundamentals remain constant, particularly the value and necessity of sound judgment, technical rigor, and the notion of trust but verify.
This article does not necessarily reflect the opinion of Bloomberg Industry Group, Inc., the publisher of Bloomberg Law, Bloomberg Tax, and Bloomberg Government, or its owners.
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