The U.S. Department of the Treasury and the Internal Revenue Service (IRS) have formally clarified that corporations will not be subject to taxation on unrealized gains on Bitcoin under the Corporate Alternative Minimum Tax (CAMT).
Specifically, the interim guidance, released on Tuesday, addresses a critical issue for companies that maintain substantial cryptocurrency holdings.
What the Guidance Means
The CAMT, enacted through the Inflation Reduction Act of 2022, imposes a 15% minimum tax on corporations with average annual financial statement income exceeding $1 billion. However, pursuant to the newly issued clarification, corporations may exclude unrealized gains and losses on digital assets in determining adjusted financial statement income (AFSI).
Consequently, corporations will not incur tax liabilities based on cryptocurrency price fluctuations unless such gains are realized through actual transactions. Furthermore, the Treasury has indicated its intent to promulgate revised regulations in alignment with this interim guidance.
Industry Concerns Resolved
Before this clarification, lawmakers and industry stakeholders had expressed concern that taxing unrealized gains could compel corporations to liquidate digital assets to cover tax obligations. In light of this, Senator Cynthia Lummis welcomed the update, calling it essential for protecting firms that build Bitcoin treasuries.
Overall, the ruling is seen as an effort to encourage digital asset adoption in U.S. corporate finance. At the same time, it aims to prevent tax policies from discouraging innovation and long-term investment in emerging technologies.
Strategy Inc. Emerges as a Key Winner
In particular, Strategy Inc., formerly MicroStrategy, stands among the biggest beneficiaries. The company, led by co-founder Michael Saylor, is the largest corporate holder of Bitcoin.
Following the announcement, Strategy said it no longer expects to fall under CAMT in 2026, as previously projected. Its shares rose as much as 3.7% in premarket trading on Wednesday.
The company reported an $8.1 billion unrealized gain in the first half of 2025 amid a rise in Bitcoin’s price. As of this writing, it holds approximately $74.6 billion worth of Bitcoin.
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