The Bitcoin sector received encouraging news as the U.S. Department of the Treasury and the IRS issued temporary guidance on the Corporate Alternative Minimum Tax (CAMT). The guidance is designed to ease compliance for corporations and also covers firms in the digital asset sector.
In brief
- •The U.S. Treasury and IRS released interim guidance on the Corporate Alternative Minimum Tax to give companies more certainty while final rules are being developed.
- •The new guidance revised the definition of adjusted financial income so digital assets would not create tax bills on value changes that remain unrealised.
CAMT and the Crypto Industry
CAMT was introduced under former President Joe Biden through the Inflation Reduction Act of 2022. The tax imposes a 15% minimum on the adjusted financial statement income (AFSI) of large corporations. It applies to companies with an average annual AFSI exceeding $1 billion, while certain entities, including S corporations, real estate investment trusts, and regulated investment companies, are excluded. The rule ensures that major corporations pay at least a minimum tax, regardless of deductions or other adjustments.
Concerns arose for cryptocurrency companies because of how digital assets are accounted for. Under Financial Accounting Standards Board rules, firms must “mark-to-market” their cryptocurrency holdings, recording their value based on current market prices, even if no sale occurs. While unrealised gains on stocks are generally excluded from CAMT, digital assets were not clearly exempt.
This treatment could have resulted in significant tax liabilities for firms with large Bitcoin holdings. Strategy, which holds over 640,000 Bitcoin, risked facing a significant CAMT bill on gains that were only unrealised.
To address these concerns, Strategy and Coinbase sent a joint letter to the Treasury in May, requesting that unrealised gains and losses on digital assets be excluded from AFSI.
New Notices Clarify CAMT Rules
The latest interim guidance provided clarity, explaining how companies should handle CAMT while final rules are still being developed:
- •The guidance, issued in Notices 2025-46 and 2025-49, aims to ease compliance and simplify complex areas of the Corporate Alternative Minimum Tax.
- •Notice 2025-49 outlines how CAMT applies under Sections 55, 56A, and 59 of the Internal Revenue Code, giving companies concrete instructions for reporting.
- •It also revises the definition of Adjusted Financial Statement Income (AFSI), ensuring that companies holding digital assets are not taxed on gains or losses that have not yet been realised under CAMT.
Industry and Political Reactions
The guidance has been welcomed by both the crypto community and policymakers. Senator Cynthia Lummis described the development as a practical solution that allows American companies to maintain Bitcoin reserves without risking excessive tax exposure. Similarly, Michael Saylor, co‑founder of Strategy, noted that the company does not expect to face CAMT liability on its Bitcoin holdings as a result of the guidance.
The interim guidance represents a move toward clearer regulations for the crypto sector, supporting responsible corporate adoption of digital assets while offering companies clear direction at the intersection of accounting standards and tax rules.