The Senate Finance Committee will hold a hearing Wednesday on cryptocurrency taxation, one day after the Treasury Department and the Internal Revenue Service (IRS) issued interim guidance adjusting how the Corporate Alternative Minimum Tax (CAMT) applies to digital asset companies.
The guidance, set out in Notice 2025‑46 and Notice 2025‑49, is intended to “reduce compliance burdens and provide clarity on complex areas of the CAMT” until final regulations are in place. CAMT, created under the 2022 Inflation Reduction Act, sets a 15 % minimum tax on the book income of corporations with at least $1 billion in annual profits.
Notice 2025‑49 clarifies that companies may exclude unrealized gains and losses on digital assets held at fair value from adjusted financial statement income, narrowing the tax base for firms with large crypto holdings. The measure addresses concerns that accounting treatment of volatile digital assets could inflate corporate minimum tax liabilities.
“Depending on the applicable financial accounting principles, this interim guidance may apply to holdings of digital assets,” the IRS notice stated.
Investor Takeaway
Impact on Large Bitcoin Holders
According to journalist Eleanor Terrett, the rule change directly affects companies such as Michael Saylor’s Strategy, which controls over 640,000 Bitcoin with $13.5 billion in year‑to‑date unrealized gains. Without the relief, those paper gains would have been factored into CAMT, exposing the firm to billions in additional tax obligations.
The interim guidance reflects growing recognition that digital asset accounting standards differ sharply from other asset classes, and that tax rules must be adapted accordingly. Industry groups have argued that taxing unrealized crypto gains would distort company financials and discourage institutional holdings of Bitcoin and other tokens.
Senate Finance Committee Hearing
The IRS move came a day before the Senate Finance Committee’s hearing on “Examining the Taxation of Digital Assets,” chaired by Sen. Mike Crapo. Witnesses include Lawrence Zlatkin, vice president of tax at Coinbase, and Jason Somensatto, policy director at Coin Center. The panel is expected to discuss how existing securities and commodities tax rules should apply to cryptocurrencies and other digital assets.
The hearing follows recommendations published in July by the White House Digital Asset Working Group, which urged Congress to recognize digital assets as a distinct category and tailor tax treatment accordingly. The group called for clear guidance to reduce uncertainty for companies operating in the sector.
Investor Takeaway
Next Steps for Digital Asset Tax Policy
Lawmakers are under pressure to reconcile the growth of crypto markets with a tax system built around traditional securities. Interim guidance such as Notice 2025‑49 is only temporary, and the Treasury is expected to propose permanent regulations later this year. Industry participants will watch closely for whether Congress directs further adjustments as part of broader digital asset legislation.
For now, the relief on unrealized crypto gains removes one of the immediate risks facing large corporate Bitcoin holders. The Senate’s debate on Wednesday will test how far lawmakers are prepared to go in aligning tax policy with a rapidly expanding digital asset economy.