This week, Assaf Harpaz (Georgia) presented two new papers:

• Taxing AI at the New Scholars Workshop at the Association of American Law Schools (AALS) Annual Meeting in New Orleans (Jan. 9, 2026); and
• Tax Sovereignty at the Junior International Law Scholars Association (JILSA) Annual Meeting at the William S. Richardson School of Law University of Hawai‘i at Mānoa (Jan. 7, 2026).

Abstracts follow.

Assaf Harpaz, Taxing AI:

The federal tax system serves three principal goals: revenue raising, redistribution, and regulation of taxpayer behavior. To achieve these goals, it disproportionately relies on the taxation of individual labor income and payroll, rather than on capital or consumption. The integration of artificial intelligence (AI) is poised to change the sources and distribution of income, with some experts predicting widespread job displacement. Even under optimistic projections, AI is expected to exacerbate wealth inequality, given that the technology’s ownership and immense value are concentrated within a subset of Big Tech companies and AI startups.

Scholars and policymakers have advanced a broad range of tax policy responses to AI’s impacts. Existing proposals can generally be divided into taxes on firms that replace human labor (“robot taxes”) and calls to assign legal personhood to AI. This Article reframes the debate by shifting the focus from AI models to the tax system itself, inquiring how the system can sustain its purposes amid the rise of AI.

This Article promotes a functionalist methodology to analyze the tension between AI and the goals of the federal tax system. It argues that AI threatens to disrupt the tax system’s ability to fulfill its core objectives. The risk is heightened by the federal government’s heavy dependence on individual labor income, even as economic value shifts toward mobile capital and AI ownership by large firms. The Article proposes two interventions that aim to rebalance the tax base. In the short term, it recommends increasing the capital gains rates on the sale of ownership interests in AI-intensive firms. In the long term, it suggests adopting a broad-based consumption tax if the share of labor income declines.

Assaf Harpaz, Tax Sovereignty:

Tax sovereignty is gaining significant attention in international tax policy. The concept traditionally refers to a government’s authority to design and enforce its own tax laws, without infringement. Policymakers are increasingly invoking the principle to broaden their country’s assertions of taxing rights (e.g., on offshore profits) and to withdraw from international agreements that they deem unfavorable. While tax sovereignty has been widely debated in legal scholarship, its parameters are not clearly established. These tensions have emerged in recent negotiations on issues like the global minimum tax and the legitimacy of tax havens, highlighting the need to better conceptualize the principle. 

This Article explores the origins of the tax sovereignty principle and its proliferation in the current international tax discourse. It develops a doctrinal account of tax sovereignty that illuminates the obligations and limitations embedded within the concept. The Article argues that tax sovereignty operates as a legally bounded doctrine rather than an unrestricted claim of fiscal autonomy, especially if a sovereign’s policies create negative externalities to others.