Reframing Bitcoin and Tax Compliance

30 Pages Posted: 25 Feb 2020

See all articles by Arvind Sabu

Arvind Sabu

Office of Chief Counsel, IRS

Date Written: August 11, 2019


This Article argues that, contrary to the common belief that Bitcoin enables tax evasion, the Internal Revenue Service (“IRS”) can increasingly police transactions in Bitcoin. First, commercial and technical intermediaries have emerged as part of Bitcoin’s ecosystem. This diverse set of intermediaries can facilitate tax enforcement, as the litigation over the IRS’s summons on Coinbase—the largest domestic digital asset exchange—and subsequent IRS efforts show. These intermediaries could report transactions to the IRS or even, one day, withhold and remit tax payments. Second, the publicly visible, trustworthy nature of Bitcoin’s blockchain—its unique role as a shared truth—allows tax authorities to observe transaction flows. This renders Bitcoin unusually regulable for tax purposes, as recent efforts by the IRS to rely on Bitcoin’s blockchain to police tax evasion demonstrate. The Article offers a proposal by which the IRS might make better use of Bitcoin’s blockchain: the IRS can tailor an existing program to reward technically savvy whistleblowers who scour Bitcoin’s blockchain and determine identities that correspond to public Bitcoin addresses at issue.

Keywords: Bitcoin, tax evasion, cryptocurrency, tax compliance

Suggested Citation

Sabu, Arvind, Reframing Bitcoin and Tax Compliance (August 11, 2019). 64 ST. LOUIS U. L.J. ___ (2020, Forthcoming), Available at SSRN:

Arvind Sabu (Contact Author)

Office of Chief Counsel, IRS ( email )

200 W. Adams St.
Chicago, IL 60606
United States
3123688251 (Phone)

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