If you happened to prepare your own tax return this year or at least looked at the top of the first page, you might have noticed that the IRS has literally moved cryptocurrency transactions to the top.  We recently published an article in Bloomberg’s Tax Management Memorandum that looked at the aggressive moves the IRS is taking with respect to cryptocurrency.  We looked at the disparate ways that the various U.S. government agencies define cryptocurrency, as well as efforts by the IRS to increase the revenue stream to the government from cryptocurrency transactions.  We also looked at enforcement efforts by the IRS, as well as reporting and withholding obligations that might come to the fore based on past IRS enforcement activity.  The article may be found here.

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David Zaslowsky is partner in the Litigation Department of Baker McKenzie's New York office. He helps companies solve complex commercial disputes in arbitration and litigation, especially those involving cross-border issues and Section 1782 discovery. David has a degree in computer science and, as a result, has worked on numerous technical-related disputes, including, most recently, those involving blockchain and artificial intelligence. In April 2025, Attorney Intel named David one of the top 25 blockchain lawyers in the country. He is the editor of the Firm's blockchain blog and co-editor of the firm's International Litigation & Arbitration Newsletter. David has been included for a number of years in the Chambers USA Guide and Chambers Global Guide for his expertise in international arbitration. He also sits as an arbitrator and is on the roster of arbitrators for a number of arbitral institutions. David sits on the Board and chairs the governance committee of the New York International Arbitration Center, and is a founding member of the International Arbitration Club of New York. For over 35 years, he has written and spoken often on the subjects of arbitration and international litigation.

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Scott Frewing represents clients in complex civil and criminal tax matters, as well as other complex financial investigations and litigation. He has successfully defended taxpayers from some of the largest transfer pricing cases brought by the US Internal Revenue Service, obtained multiple tax refunds in excess of USD100 million, and successfully represented financial institutions and individuals in IRS and US Department of Justice investigations relating to offshore tax accounts and other allegations of tax fraud. Earlier in his career, Mr. Frewing was a federal prosecutor and was a founding member of the US Department of Justice’s first Computer Hacking and Intellectual Property Unit.