CARF’s Impact on the Crypto Marketplace: An Equal and Opposite Reaction?

In this article centred on the OECD’s Crypto-Asset Reporting Framework (CARF), a leading US tax practitioner based in Zurich shares his expectations on the fall-out from the incoming crypto asset reporting regimes. Grounding his views in precedents from recent tax reporting for conventional asset classes, he forecasts resistance from the industry and investors, leading to novel enforcement challenges faced by tax authorities when confronted by an agile and motivated target. In closing, he sets out a series of enhanced enforcement proposals that tax authorities might adopt to further CARF compliance.

Authors

Publication Details

Journal
Intertax
Published
2026-02-16
DOI
https://doi.org/10.54648/taxi2026028
Primary Topic
Corporate Taxation and Avoidance
Type
article
Field-Weighted Citation Impact
0.00
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article

CARF’s Impact on the Crypto Marketplace: An Equal and Opposite Reaction?

Paul Foster Millen
Intertax
Corporate Taxation and Avoidance
article

CARF’s Impact on the Crypto Marketplace: An Equal and Opposite Reaction?

Paul Foster Millen
article en

Abstract

In this article centred on the OECD’s Crypto-Asset Reporting Framework (CARF), a leading US tax practitioner based in Zurich shares his expectations on the fall-out from the incoming crypto asset reporting regimes. Grounding his views in precedents from recent tax reporting for conventional asset classes, he forecasts resistance from the industry and investors, leading to novel enforcement challenges faced by tax authorities when confronted by an agile and motivated target. In closing, he sets out a series of enhanced enforcement proposals that tax authorities might adopt to further CARF compliance.

IntertaxVol. 54(Issue 3)
Openalex Percentile: Top 55%
Corporate Taxation and Avoidance
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CARF’s Impact on the Crypto Marketplace: An Equal and Opposite Reaction? — Paul Foster Millen · Intertax (2026) | TGRS Research Map | TGRS