The U.S. Treasury Department and the Internal Revenue Service have released interim guidance to significantly ease the tax burden on companies that own Bitcoin and other digital assets.
Published on September 30th, The Notices, 2025-46 and 2025-49, clarify how the Alternative Minimum Tax (CAMT) for Enterprises applies to unrealized benefits.
This guidance follows intense feedback regarding the proposed regulations (REG-112129-23) published in September 2024. These rules left companies uncertain about how unrealized cryptocurrency profits would be treated under the CAMT framework.
By addressing this gap, the Treasury and the IRS aim to reduce compliance costs and clarify how companies calculate the CAMT's tax base, Adjusted Financial Statement Revenue (AFSI). Companies may immediately rely on this interim relief, where future regulations expect similar provisions.
Created by the 2022 Inflation Reduction Act, CAMT imposes a 15% minimum collection on companies reporting at least $1 billion in average annual AFSI.
That calculation included unrealized digital assets profits without adjustments, causing enormous paper tax liability for businesses with potentially large crypto-holdings.
Bitcoin Finance Company Relief
The update will have an immediate impact on companies such as Strategy Inc. (formerly MicroStrategy), which holds over 640,000 BTC.
Under the accounting standards adopted in January 2025, the strategy is currently reported at fair value by Bitcoin, with unrealized profits and losses flowing into net income quarterly.
Before this guidance, analysts predicted that the company would fall into CAMT in 2026, revealing billions of liabilities with potential liability for unrealized Bitcoin profits.
However, the new rules allow companies to exclude unrealized cryptocurrency benefits from AFSI.
As a result, the strategy no longer expects to face CAMT exposures related to $16 billion in Bitcoin Holdings. That shift removes the major overhangs regarding the company's long-term strategy of holding Bitcoin as a reserve asset.
With over 100 public companies holding more than 1 million BTCs, the ruling could strengthen Bitcoin's role as a corporate preparatory tool.
With this in mind, Bitcoin Advocates welcomed the move as a verification by the Ministry of Corporate Finance.
Investor Peter Duan emphasized that the IRS clarification would give businesses certainty and encourage them to continue to accumulate BTC without the threat of taxation on paper profits.
Asset Management's Jeff Walton reflected that view, claiming that the decision would remove the “large FUD narrative” that discouraged companies from reporting the profits of strong digital assets.
