The U.S. Treasury Department along with the Internal Revenue Service has issued interim guidance that greatly alleviates tax obligations for corporations owning Bitcoin and other digital currencies.
Released on Sept. 30, the notifications, 2025-46 and 2025-49, clarify the application of the Corporate Alternative Minimum Tax (CAMT) to unrealized gains, a concern that had alarmed corporate treasuries.
This guidance responds to extensive feedback on proposed regulations (REG-112129-23) released in September 2024. Those rules left companies unclear on how unrealized crypto gains would be treated within the CAMT framework.
By addressing this gap, the Treasury and the IRS aim to lower compliance expenses and provide clarity on how firms should compute their adjusted financial statement income (AFSI), the tax base for CAMT. Companies can immediately take advantage of this interim relief, with similar provisions anticipated in future regulations.
The CAMT, established by the 2022 Inflation Reduction Act, imposes a minimum tax of 15% on corporations declaring at least $1 billion in average annual AFSI.
This calculation would have involved unrealized digital asset gains without any adjustments, potentially creating significant paper tax liabilities for firms with substantial crypto holdings.
Support for Bitcoin treasury firms
The update has immediate consequences for firms like Strategy Inc. (formerly MicroStrategy), which holds over 640,000 BTC.
With accounting standards adopted in January 2025, Strategy now reports its Bitcoin at fair value, with unrealized gains and losses reflected in net income quarterly.
Prior to this guidance, analysts predicted the company would be subject to CAMT in 2026, leading to billions in potential liabilities on unrealized Bitcoin gains.
However, the new rules will allow the company to exclude those unrealized crypto gains from AFSI.
Consequently, Strategy no longer anticipates facing CAMT exposure related to its $16 billion in Bitcoin assets. This change alleviates a significant burden on the company’s long-term strategy of using Bitcoin as a reserve asset.
With over 100 public companies holding more than 1 million BTC, this ruling could enhance Bitcoin’s status as a corporate reserve asset.
In light of this, Bitcoin supporters welcomed the decision as a confirmation for corporate treasuries.
Investor Peter Duan emphasized that the IRS clarification provides companies with certainty, motivating them to continue acquiring BTC absent the risk of tax on unrealized gains.
Jeff Walton of Strive Asset Management supported this perspective, arguing that the ruling eliminates a “massive FUD narrative” that had deterred companies from reporting substantial digital asset gains.
