Compliant by Design
A Circular 230 Framework for Delivering AI-Assisted Tax Strategy to Underserved Taxpayers
In 2026 the IRS made every tax practitioner personally responsible for the output of any AI they use, yet most firms have adopted these tools with no governance at all. This paper argues that safe, scalable AI in tax practice is a design problem, and proposes a framework that builds each Circular 230 duty (verifiability, bounded competence, human oversight, confidentiality, auditability and disclosure) into the architecture of the tool.
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