It really depends on how many games you plan on downloading. Some games are not very big but I'm sure most games are already crossing the 1GB mark, at least the more major releases.
Actually, you can live with 16 GB and 32 GB should be enough for anyone. 64 GB seems like overkill, but it certainly won't hurt. Big games are around 1 GB and 2 GB, impossibly humongous games like Bravely Default are somewhere between 2 and 4 GB (lots of voice acting will do that to a game's size), and most games are anywhere between 300 MB and 1 GB.
I'm using a 32GB and have downloaded about two retail games, a bunch of eShop games, and a lot of demos and I've got about 15GB left. So it really depends on how many games you're planning on buying.
I'm using 32GB when I switch from Regular 3DS to 3DS XL last year and I been buying my games digital besides Pokemon Y cause the Download size is 14,000GB and that's just too damn high. It really depends on how many 3DS games you will buy but with the N3DS right around the corner, I imagine that the games GB will go up but again, if you think your gonna download a lot of 3DS games, then I think 32GB is best and they are really cheap depends on which hardware market you go.
Quick update: The Japanese version of Super Smash Bros. is a 2.1 GB download. Given that Nintendo aren't known for adding too much voice acting to their games, chances are that's as big as a first party game is going to get.
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