Five Questions With EisnerAmper Tax Partner Dean Peterson

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. This week’s answers are from Dean Peterson, partner-in-charge of EisnerAmper’s international tax practice.

What is the biggest challenge that tax practitioners are facing in 2026?

It’s navigating a tax and trade environment that’s defined by structural uncertainty, where the rules are changing faster than businesses can adapt. Look at the recent US Supreme Court decision invalidating the IEEPA tariffs and the administration’s quick action to implement new tariffs under Section 122 of the Trade Act of 1974. These tariffs are now at 10% on many imports.

While these tariffs have a 150-day clock and no clear congressional path to extension, companies are making long-term supply chain, structuring, and transfer pricing decisions without knowing what the landscape will look like in six months.

What tax issue keeps you up at night?

The growing divergence between the US and the rest of the world on international taxation. The 15% global minimum tax was adopted by more than 140 countries, and our clients with US parent companies are now subject to top-up taxes in jurisdictions that have enacted the tax under Pillar Two. This is due to misalignment between the US and the rest of the world.

In January 2026, the OECD released “side-by-side” rules that would exempt certain multinationals from the scope of two key aspects of Pillar Two: the Income Inclusion Rule and Undertaxed Profits Rule. Multinationals with an Ultimate Parent Entity in a jurisdiction with a “Qualified Side-by-Side Regime” could elect a deemed top-up tax of zero under both the IIR and UTPR across all domestic and foreign operations.

As of January 2026, the US is the only country meeting the eligibility criteria, as the qualifying conditions were designed around the the US tax system. Under the side-by-side agreement, the US tax system would effectively operate in parallel to the Pillar Two rules.

While the side-by-side rules are a significant step, there are many unresolved differences between US and the rest of the world on global taxation.

What tax case is no one watching that they should be?

It’s United States v. Sagoo. The Northern District of Texas ruled that taxpayers are guaranteed a jury trial before Foreign Bank and Financial Account Report penalties for willful failure to file can be assessed. In Sagoo, the court found that, pursuant to SEC v. Jarkesy, FBAR penalties are subject to the Seventh Amendment right to a jury trial prior to assessment.

The IRS was found to have violated Sharnjeet Sagoo’s Seventh Amendment right. This has serious implications on the FBAR penalty program, which requires a pre-litigation assessment.

Sagoo will likely cause the IRS to reshape its FBAR compliance efforts, possibly implementing more selective enforcement or shifting focus from enforcement to its streamlined voluntary disclosure program. In short, Sagoo potentially upends long-established IRS FBAR enforcement practice and introduces a constitutional constraint. If Sagoo holds in other circuits, it is unclear how the IRS can bring any FBAR penalty cases at all.

What’s the biggest lesson you learned in your early years of practice?

The human connections with your colleagues and clients make a world of difference. A career in this profession is built on earning trust and fostering relationships that can grow over many years.

I also learned there is no substitute for hard work paired with genuine curiosity. The mentors that I most admired over the years were those who were endlessly curious, always prepared, and generous with their knowledge and time. I try to carry those qualities into how I build and lead my own team. If I had to distill it to one sentence: Technical excellence opens the door, but the relationships you build will determine how far you go.

What was the last thing you believed beyond a reasonable doubt?

Income is income from whatever source derived, unless specifically excluded by law.

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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