US Eases Bitcoin Tax Rules for Corporations

The US Treasury Department and Internal Revenue Service issued interim guidance on September 30 through Notices 2025-46 and 2025-49, resolving a critical uncertainty that had plagued corporate treasuries since proposed regulations were published in September 2024. The guidance specifically addresses how the Corporate Alternative Minimum Tax (CAMT) applies to unrealized gains on digital assets like Bitcoin, a question that had raised alarm across corporate finance departments. Following heavy industry feedback on the proposed regulations (REG-112129-23), Treasury and IRS officials moved to clarify how firms calculate their adjusted financial statement income (AFSI), the tax base for CAMT.

Created by the 2022 Inflation Reduction Act, the CAMT imposes a 15% minimum levy on corporations reporting at least $1 billion in average annual AFSI. Without the new guidance, this calculation would have included unrealized digital asset gains without adjustments, potentially creating enormous paper tax liabilities for companies with significant crypto holdings. The interim relief allows corporations to immediately rely on these provisions while awaiting final regulations, significantly reducing compliance costs and administrative burdens.

The updated tax guidance has immediate and profound implications for companies like Strategy Inc. (formerly MicroStrategy), which holds more than 640,000 BTC valued at approximately $16 billion. Under accounting standards adopted in January 2025, Strategy now reports its Bitcoin at fair value, with unrealized gains and losses flowing into net income each quarter. Before this guidance, financial analysts expected the company to fall under CAMT in 2026, exposing billions in potential liability on unrealized Bitcoin gains.

The new rules allow Strategy to exclude those unrealized crypto gains from AFSI calculations, meaning the company no longer expects to face CAMT exposure linked to its massive Bitcoin holdings. This fundamental shift removes a major strategic overhang on the company’s long-term approach of holding Bitcoin as a primary reserve asset. The clarity provided by the IRS and Treasury effectively validates Strategy’s corporate treasury strategy and eliminates what could have been a crippling tax liability on paper profits.

With more than 100 public companies collectively holding over 1 million BTC, the Treasury ruling could significantly strengthen Bitcoin’s position as a corporate reserve instrument. The elimination of tax uncertainty surrounding unrealized gains removes a critical barrier that had discouraged corporations from reporting strong digital asset performance. Industry experts immediately recognized the broader implications for corporate adoption of cryptocurrency as treasury assets.

Investor Peter Duan emphasized that the IRS clarification provides corporations with the certainty needed to continue accumulating BTC without the threat of taxation on paper profits. Jeff Walton of Strive Asset Management echoed this perspective, arguing that the decision eliminates what he called a ‘massive FUD narrative’ that had discouraged companies from reporting substantial digital asset gains. The collective industry response suggests the ruling could accelerate corporate Bitcoin adoption by removing a significant regulatory uncertainty that had hampered treasury strategies.

The guidance represents a pragmatic approach by US regulatory authorities to emerging digital asset accounting challenges. By addressing the treatment of unrealized gains specifically within the CAMT framework, Treasury and IRS officials have created a more predictable environment for corporate cryptocurrency holdings. This development comes at a critical juncture as more corporations consider digital assets as part of their treasury management strategies, potentially marking a turning point in institutional cryptocurrency adoption.