Significant relief from tax obligations is on the horizon for businesses holding Bitcoin and various other digital currencies, thanks to freshly released interim guidance from the US Treasury Department in conjunction with the Internal Revenue Service.
The notices, identified as 2025-46 and 2025-49, were published on September 30th and offer clarification on the application of the Corporate Alternative Minimum Tax (CAMT) concerning unrealized gains. These gains were a point of considerable concern for corporate finance departments. You can view these notices here.
This guidance comes as a direct response to extensive feedback received on proposed regulations (REG-112129-23) released in September of the previous year, 2024. These earlier regulations caused uncertainty among corporations regarding the treatment of unrealized cryptocurrency profits under the CAMT structure.
By addressing these grey areas, both the Treasury and the IRS intend to lower the costs of adherence and to offer clarity on how companies determine their adjusted financial statement income (AFSI), which forms the foundation for CAMT calculations. Companies can immediately adopt this temporary relief, and similar regulations are expected to be formalized in upcoming rulings.
The CAMT, which was established as part of the Inflation Reduction Act of 2022, mandates a minimum tax of 15% on corporations whose average annual AFSI is at least $1 billion.
Without the new adjustments, this calculation would have incorporated unrealized digital asset profits, which could have resulted in substantial paper tax liabilities for organizations with significant cryptocurrency holdings.
Tax Relief for Bitcoin-Holding Businesses
This amendment has direct implications for firms such as Strategy Inc. (formerly known as MicroStrategy), an organization that possesses over 640,000 BTC.
In accordance with accounting standards that came into effect in January 2025, Strategy now reports its Bitcoin at its fair market value, with unrealized gains and losses affecting net income quarterly.
Prior to this recent guidance, analysts predicted that the company would fall under CAMT regulations in 2026, potentially incurring billions in liabilities on unrealized Bitcoin gains.
However, under the revised regulations, the company would be permitted to exclude these unrealized cryptocurrency profits from its AFSI.
As a result, Strategy anticipates no longer facing CAMT exposure in relation to its $16 billion Bitcoin investment. This change alleviates a significant burden on the company’s long-term strategy of maintaining Bitcoin as a reserve asset.
Given that over 100 publicly traded companies hold more than 1 million BTC, this ruling could reinforce Bitcoin’s status as a viable corporate reserve instrument.
In light of these developments, Bitcoin proponents have hailed the decision as a validation for corporate treasuries.
Investor Peter Duan emphasized that the IRS’s clarification provides firms with the certainty they need to continue accumulating BTC without the fear of taxation on unrealized profits.
Jeff Walton from Strive Asset Management concurred with this viewpoint, asserting that the decision eliminates a “significant FUD narrative” that had discouraged companies from openly reporting strong digital asset profits.