Five Questions With Baker McKenzie Tax Chair Maria Eberle

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 Maria Eberle, chair of Baker McKenzie’s Americas tax practice group and a partner in the firm’s New York office.

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

Tax practitioners are facing constant and accelerating change, from legislation and guidance to enforcement priorities and technology. Our value increasingly lies in our ability to see around corners, anticipate what’s coming, and help clients prepare for the unexpected.

At the same time, we must find efficiencies by embracing tools such as artificial intelligence while ensuring we don’t lose the creativity, judgment, and practical insight that define effective tax advice. The challenge isn’t just adapting to change but doing so thoughtfully and strategically.

What tax issue keeps you up at night?

It’s the prospect that a tax authority can reinterpret a written rule after the fact and assert, “This is what we always meant.”

Taxpayers make real-world decisions based on the law, guidance, and facts as they exist at the time those decisions are made, and they should be able to rely on that framework. Retroactive reinterpretation erodes certainty and fairness in the tax system and undermines confidence in the rules themselves.

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

Mistakes are inevitable. What defines you isn’t the mistake itself but how you respond to it. Early on, I learned the importance of taking ownership, addressing issues directly, and focusing on solutions rather than defensiveness. That lesson has stayed with me as my responsibilities have grown.

As a leader, I try to model accountability and transparency, both with clients and with teams. I encourage people to raise issues early and to approach problems thoughtfully and collaboratively. In my experience, that approach builds trust, strengthens judgment, and ultimately leads to better outcomes for clients and stronger teams. Hiding isn’t an option.

What’s the most memorable case you’ve worked on?

The most memorable case I worked on was a New York state tax matter for a large medical device company. The issue was whether licenses of intangible rights granted in connection with the use of an excimer laser machine were subject to New York sales-and-use tax.

When I joined the case, there was widespread skepticism about our chances of success because the tax department had issued a technical release taking an adverse position. However, that release wasn’t entitled to special deference, and its reasoning was inconsistent with the governing law. We ultimately prevailed—despite the naysayers.

An additional highlight was the opportunity to call as an expert witness the former head of the US Patent and Trademark Office under the Reagan administration. I had the chance to prepare him for testimony, which deepened my understanding of both patent law and the technical operation of the laser itself—so much so that I used to joke with friends and family that I could probably perform the procedure myself.

Overall, the case was an extraordinary experience, combining the challenge of building a winning legal argument with the rare opportunity to work closely with a high-profile expert witness.

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

It’s that if a tax authority (whether it be the IRS, state revenue agency, or foreign government) believes that there is a viable adjustment to be made, they will pursue it relentlessly. The facts may change, the legal theories may shift, but a taxing authority rarely walks away once it believes it has made a worthy adjustment.

This article does not necessarily reflect the opinion of Bloomberg Industry Group, Inc., the publisher of Bloomberg Law and Bloomberg Tax, or its owners.

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