Who’ll Own Your Inevitable AI Assistant? The Battle Is On, and I Predict One Winner


Welcome to CNET’s new series of guest columns called Alt View, a forum for a diverse array of experts and luminaries to share their insights into the rapidly evolving field of artificial intelligence. For more AI coverage, check out CNET’s AI Atlas.


Every great technology gives humans a new superpower. The personal computer put the power of computing into the hands of individuals, turning machines once reserved for governments, universities and corporations into tools anyone could use. The internet gave us access to the world’s information. The smartphone put that power in our pockets, connecting us to anyone and anything from almost anywhere.

Each breakthrough changed what one person could do. But even with all this technology, we’re still the ones doing a lot of the work. We schedule meetings, organize our inboxes, manage dozens of apps, absorb endless amounts of information and make thousands of small decisions every day.

In platform shifts, tech feels like a tool before it becomes something bigger. AI is in that moment now. We mostly experience AI as something we ask questions of or give tasks to. But the breakthrough comes when AI understands, not just responds. 

A glowing translucent lightbulb, held by a hand, in front of lighted lines suggesting a circuit board

I’ve spent my career experiencing and even causing platform shifts. The Mac. The iPod. The iPhone. Nest. Every one of these transitions had something in common: taking a capability that used to be rare, difficult or expensive and making it more accessible. The builders who understood the behavioral shift, not just the technology shift, were the ones who built something that lasted.

AI assistants are the next big shift.

A handful of people have had another kind of superpower: a great assistant. It’s a superpower not because someone answers their emails or books their flights – those are helpful tasks. The real value of an assistant is that they understand the person behind the tasks: who you are, your relationships, your routines, your family, what you prioritize and what keeps you up at night. They know what to handle, what to bundle together and what truly needs your attention. 

A great assistant can anticipate what you need before you even ask. But that relationship doesn’t happen overnight. It takes years of working together, learning patterns, building trust and accumulating context.

Once you have that superpower, you never want to lose it. Losing a great assistant means losing years of shared knowledge and understanding. That accumulated understanding is what transforms an assistant from someone who helps you complete tasks into someone who expands what you can do. 

Most people have never had an assistant or seen how a great one actually works, which means we are learning two things at once: what an assistant can do and what AI can become. 

AI is beginning to act as a painkiller. It can remove friction, automate some tasks and help us move faster. But we still manage AI more than AI manages us. We prompt, correct and guide. That will change. 

A painkiller removes the pain you already feel. A superpower goes beyond removing pain. It unlocks new capabilities you couldn’t even have imagined. However, building an AI assistant that gives you these superpowers requires a lot more context than what we’ve got right now.

These are the moments in technology that matter. When a new capability forces us to rethink what’s possible and what we should expect from the products in our lives.

Building an AI assistant

A freelancer juggling three clients, six deadlines and a stack of unpaid invoices will soon have an AI assistant that keeps track of it all, so they can focus on the work instead of the overhead. A parent will use it to manage the family calendar, school reminders, grocery lists and doctor’s appointments. A student will have it organize coursework, prepare for exams and stay on top of deadlines. An aging adult will rely on it for medication reminders and appointment coordination.

An AI assistant isn’t a chatbot. It isn’t a single model or one agent completing a task. Those are pieces of the solution. A great AI assistant isn’t one thing. Like every great product, an AI assistant is the result of many technologies working together seamlessly to create one simple experience. Soon your AI assistant won’t just tell you your flight is delayed. It will understand why that delay matters, rebook it, notify the people you’re meeting and update your calendar.

Context gives the assistant awareness. The ability to know if you’re at work, at home, traveling, in a meeting, exercising or spending time with family. The richer the context, the more useful and personalized your assistant becomes. 

Memory allows the assistant to learnyour preferences, workflows, habits, relationships, routines and prior conversations over time.

The right interaction and personality build trust. Every assistant develops a communication style, tone and patterns that feel natural to the person using it.

Skills give assistants the ability to get things done: research, coding, scheduling, financial analysis, design tools, travel coordination, health tracking or interacting with other specialized agents.

And finally, reflection, the ability for an assistant to synthesize information across your workflows, interests, relationships and routines to identify patterns and surface useful insights you wouldn’t have found on your own.

Together they’re what turn AI from a tool that responds into an AI assistant that understands you.

The AI assistant adoption curve

Most people still don’t know they need an AI assistant. That’s not unusual for a new platform. In the early days of personal computing, most people didn’t understand why they’d ever need a Mac or a PC. Computers felt niche, technical, and disconnected from real life. Apple understood that behaviors had to change before the platform could scale, so it got Macs into classrooms, invested in student pricing and made the product familiar before it was necessary. If you learned on Apple, Apple became second nature and trusted.

ChatGPT reached 100 million users faster than any consumer technology in internet history. People are already living with AI, but we’re still in the early stages. The next shift moves this tool from occasional chatbot to a trusted assistant working persistently by your side.

The first experiences didn’t feel like AI at all. They felt like smarter search. Now, we’re having it do simple things automatically: sports scores, weather alerts and travel itineraries. Next, the delegation increases. That’s the important shift.

The more useful an assistant becomes, the more you rely on it. The more you rely on it, the more memory accumulates and trust builds. Eventually it weaves itself into your life, helps you manage life and even enjoy life. 

The iPhone had a similar path. It started as a phone that you could use to check email. Then it became your wallet, your navigation system, your camera, your music player, your messaging platform and eventually something most people cannot leave home without. We’re still in the email-checking phase of AI assistants. There’s a lot more to unlock.

The battle for the AI assistant

Platform wars have been fought over apps, ecosystems, operating systems, developer relationships and network effects. This one is different.

The model is not the assistant. The assistant is the platform.

We’ve seen this pattern before. The iPhone brought together hardware, software, services and an ecosystem that changed how people interacted with tech. The same will be true for AI. 

Tony Fadell with an original iPod and a Nest thermostat

Tony Fadell helped create the iPod before going on to found Nest.

Tony Fadell/CNET

The AI platform war won’t be won by the model alone. Whoever builds the complete assistant experience with context, memory, interaction, skills and reflection all working together will win this war. 

You tell your AI assistant you need to go to New York for a meeting Wednesday and be home by Friday evening, for example. Without context it doesn’t know where to book the flight from. Without memory it doesn’t know you always choose an aisle seat, prefer the same Midtown hotel and need to be back home for school pickup. 

Context tells the model what’s happening right now. Memory tells it who you are. Skills allow it to act. The interaction builds trust. Reflection helps it connect patterns and anticipate what you need next. The model is the brain that processes information and generates responses. But a brain alone isn’t enough. Without the rest of the system, every interaction starts from zero.

Microsoft, Google, Apple, Anthropic, OpenAI, Perplexity and xAI are all competing to own this very personal interaction with you. Right now, for most of them, the model is their moat. But models are already commoditizing. Our personal hardware devices will plug into different AI “brains” – in the cloud or on devices themselves – whichever are cheapest, fastest or offer up more privacy.

The real moat will be the complete assistant built around you over time.

No single cloud service can see the full picture of your life. But a connected ecosystem of devices can. Your phone knows your location, your watch knows your heart rate, your laptop knows your calendar, your glasses know who you’re talking to. Each signal is useful alone. Combined, they create a much more powerful portrait the assistant can use to understand you.

This is what I call the Federation of Devices. Whoever controls this Federation of Devices has the foundation to build the most trusted and most valuable AI assistant.

The cloud doesn’t scale

A real AI assistant isn’t something you ask just a couple questions a day. It’s always helping. And that requires constant compute. If every interaction must travel to the cloud, the cost of running a truly personal AI assistant starts looking a lot more like paying for a human assistant, which is out of reach for most consumers.

The only way this scales is to move more intelligence closer to you.

Think about your home security camera. You don’t want every frame of video sent to a remote server just to detect motion. Processing happens on the device because the economics, speed and privacy demand it. Smart glasses that translate a conversation in real time can’t wait for a round trip to a data center. You’d be halfway through the sentence before the answer came back. 

AI Atlas

Your AI assistant is no different. Local AI handles the routine. Cloud models handle the complex reasoning. Companies like Plumerai are building exactly for this moment with tiny AI models small enough to run on a chip the size of a thumbnail and powerful enough to handle the tasks you need most. (Editors’ note: Tony Fadell is an investor in Plumerai.)

The future won’t be everything in the cloud or everything on device. The architecture will be distributed. That’s how you get the economics to work.

The cloud doesn’t know you’re cold

The company that controls the federation of devices wins. With 2.5 billion active devices, that’s Apple’s hand.

Google has incredible server-side infrastructure: Gemini, custom TPUs, data centers, Search, Gmail, Maps, Android and YouTube. Nobody is closer to owning the model and cloud layer. But the cloud doesn’t know you’re cold. It doesn’t know that you’re driving, your meeting just ended or who you’re talking to. Your devices do.

Apple has the iPhone, Mac, Apple Watch, AirPods, the identity layer, edge computing and one of the deepest consumer trust relationships in the history of technology. M-series chips power your Mac and iPad. A-series chips power your iPhone and Apple Watch. Both share the same unified architecture, CPU, GPU and memory on a single chip, built for AI at the edge. Apple’s Federation of Devices will run AI on device and coordinate with more powerful models in the cloud when needed. The Apple and Gemini partnership is a signal of where this is going.

The model matters less than who controls the assistant built around you, that’s the lasting advantage. You can swap the brain. You can’t swap the memory, context and trust built over time.

Questions nobody has answered yet

We’re building this plane while flying it. I’ve spent 30-plus years building products that changed how people live. I didn’t always anticipate the questions they’d raise. This time I’m asking them.

If your AI assistant understands your communication style, workflows, negotiation patterns and institutional knowledge, who owns that context when you leave a company? If it becomes deeply integrated into healthcare, what happens when providers or insurance systems change? How portable should memory and personalization be across systems?

And then there’s the question nobody in the industry wants to ask. An assistant that knows you better than most people, is always available, is endlessly patient, is never judgmental… that’s a very powerful tool. Possibly too powerful and addictive in ways we haven’t fully reckoned with. 

We built the iPhone without asking what it would do to human connection. We should ask that question now with AI.

When we chose the iPhone over an Android device, or a Mac over a PC, we were choosing a phone or a computer. This time we’re choosing something that will know how we think, work and live. That’s never happened before. Humans are at the center of this platform shift. Build it like it matters.





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The IRS’s historical abuses led Congress to create specific taxpayer rights, including rights stemming from collection due process (“CDP”) hearings. These administrative hearings are intended to pause IRS collection actions while the IRS Office of Appeals considers whether the collection is both lawful and warranted.

One might assume these rights extend to any liability assessed by the IRS. Since the IRS is part of the U.S. Treasury, it would seem logical that these rights would apply to any liability owed to the Treasury, especially when the Treasury delegates assessment authority for the liability from one of its sub-departments to the IRS, which is another one of its sub-departments.

The fact that a liability originated with another sub-department shouldn’t matter if that original sub-department never handles the liability because it has been fully delegated to the IRS, the other sub-department. However, as the Jenner v. Commissioner, 163 T.C. No. 7, case demonstrates, this assumption is incorrect. The case involves Foreign Bank Account Reporting (“FBAR”) penalties assessed by the IRS.

Facts & Procedural History

This case involves a couple who were assessed FBAR penalties for tax years 2005 through 2009. The penalties relate to foreign bank accounts that were not reported to the Treasury Department.

When the couple did not pay the penalties, the Treasury Department’s Bureau of the Fiscal Service (“BFS”) informed the couple that funds would be withheld from their monthly Social Security benefits through the Treasury Offset Program (“TOP”) to pay these penalties.

In response, the couple submitted Form 12153, Request for a Collection Due Process or Equivalent Hearing, with the IRS. The IRS issued a letter to the couple saying that FBAR penalties are not taxes and therefore not subject to CDP requirements.

The taxpayers filed a petition with the U.S. Tax Court under the CDP hearing procedures, which was the subject of the court opinion described in this article.

About FBAR Penalties

FBAR penalties can be imposed on U.S. persons who fail to report certain foreign financial accounts to the government. The reporting requirement generally applies if the aggregate value of all foreign accounts exceeds $10,000 at any time during the calendar year.

This reporting is done on FinCEN Form 114 (formerly TD F 90-22.1). The form is due on April 15th and there is an automatic extension to October 15th.

The amount of the penalties can be severe. Non-willful violations can result in penalties of $10,000 per violation. Willful FBAR violations can result in penalties of the greater of $100,000 or 50% of the account balance at the time of the violation. Criminal penalties can also apply in some situations. Notably, for purposes of this article, these penalties are assessed under Title 31 of the U.S. Code (which is the Bank Secrecy Act) and not under the Internal Revenue Code (which is Title 26 of the U.S. Code).

Assessment of FBAR Penalties

While FBAR penalties are not tax penalties, the IRS has been delegated the authority to assess FBAR penalties through a chain of delegation.

The Secretary of Treasury first delegated authority to the Financial Crimes Enforcement Network (“FinCEN”). FinCEN is a bureau of the Department of the Treasury that works to detect and prosecute financial crimes and money laundering. FinCEN then redelegated this authority to the IRS for FBAR penalties.

The typical assessment process begins when an IRS agent conducts an audit and proposes penalties. The IRS then issues Letter 3709 proposing the penalties, and account holders have 30 days to either pay the penalty, request an appeals conference, or provide additional information.

The taxpayer may also trigger an assessment by voluntarily submitting FBAR forms after the due date. The IRS will review the late filing and determine whether to impose penalties. When FBARs are filed through FinCEN’s BSA E-Filing System, the IRS receives this information through an information-sharing agreement with FinCEN. The IRS can then review these late filings as part of its normal examination process.

If the taxpayer files a timely request for appeals review

If the taxpayer files a timely request for appeals review, the IRS Office of Appeals has the ability to consider the proposed FBAR penalties, including whether the violations occurred, whether they were willful or non-willful, whether reasonable cause exists, and whether the penalty amounts are appropriate. Appeals officers can sustain, reduce, or eliminate the proposed penalties based on their review of the facts and circumstances.

They can also consider hazards of litigation, meaning they can take into account the IRS’s likelihood of success if the case were to proceed to court. This review is particularly important for willful FBAR penalties, where the government must prove willfulness by clear and convincing evidence in any subsequent litigation. Appeals officers may also consider the ability to pay and can help facilitate alternative payment arrangements if the penalties are sustained.

Remedies After Missing or Unsuccessful Appeal

If account holders miss the appeals deadline or receive an unfavorable appeals decision, there are still several options that may provide remedies.

For example, the account holder can challenge the administrative offset through Treasury procedures. When the Treasury’s Bureau of the Fiscal Service initiates an offset (such as withholding Social Security benefits), they must provide notice to the account holder. The account holder then has certain due process rights under Title 31, including the right to inspect records, request a review of the debt, and establish a payment schedule. They can also present evidence that the offset would create a financial hardship or that the debt is not valid or legally enforceable.

Account holders can also wait for the government to file suit to collect the penalties and raise their defenses in the collection suit. They do not have to pay the penalty and file a refund claim first with this option. This is different from tax assessments, where taxpayers typically must “pay first, litigate later.” When the government files suit to collect FBAR penalties under 31 U.S.C. § 5321(b)(2), the account holder can raise defenses such as reasonable cause, lack of willfulness, statute of limitations, or constitutional challenges. The government bears the burden of proving its case, including proving willfulness by clear and convincing evidence for willful FBAR penalties.

Collection Due Process Not Allowed

Notably absent from the discussion above are the IRS collection programs and procedures. That is the issue in this Jenner court case.

In Jenner, the tax court answers the question as to whether the traditional CDP hearings and rights are available for FBAR penalties. As noted by the court, FBAR penalties are not “taxes” under the Internal Revenue Code and CDP rights only apply to collection of “taxes.”

The court emphasized that the IRS’s authority to assess FBAR penalties does not convert them into tax liabilities. Instead, Title 31 provides its own separate procedures for assessment and collection. The collection mechanism for FBAR penalties is through civil action or administrative offset, not through IRS liens and levies that would give rise to CDP rights.

Thus, while the IRS may assess these penalties, they remain non-tax debts subject to Title 31’s collection procedures rather than the Internal Revenue Code’s collection provisions. The CDP hearing is not a viable option for contesting the assessment or underlying liability for FBAR penalties.

The Takeaway

Unless Congress changes the law, account holders who are assessed FBAR penalties by the IRS do not have fundamental rights, such as CDP rights, that are afforded to taxpayers for tax balances. This is the case even though the same agency whose abuses gave rise to the CDP hearing and CDP rights for taxpayers, the IRS, is involved in assessing FBAR penalties. The remedies outside of the IRS are there, even though they do not afford taxpayers the rights and remedies available for taxes. Account holders have to contend with this when assessed FBAR penalties by the IRS and do not agree with the assessments.

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