U.S. Treasury Boosts Corporate Bitcoin Adoption With New Tax Guidance
The U.S. Treasury has issued new guidance that could significantly boost corporate adoption of Bitcoin. The interim ruling allows companies to ignore unrealized gains and losses on digital assets when calculating their Corporate Alternative Minimum Tax (CAMT) liability. This comes as a relief to companies like Strategy, which held around 640,031 Bitcoins worth about $74 billion, facing a potential $27 billion tax liability due to unrealized gains.
The Inflation Reduction Act of 2022 introduced the CAMT, a 15% tax for corporations with over $1 billion in annual revenue. Initially, companies like Strategy, which holds substantial Bitcoin, were concerned about potential tax liabilities on paper profits from crypto price increases. CAMT calculates taxes based on reported financial statement values, leading to these potential liabilities.
Strategy's chairman, Michael Saylor, announced that the company would not be subject to CAMT due to unrealized gains on its Bitcoin holdings. This was made possible by the IRS's Notice 2025-49 and Notice 2025-46, which provide an 'FVI Exclusion Option'. This option allows corporations to ignore unrealized gains and losses on digital assets when calculating their CAMT liability. The guidance also addresses international competitiveness issues by aligning U.S. tax treatment with international accounting standards.
Strategy and Coinbase sent a joint letter to the Treasury in May 2025, arguing against taxing paper profits from crypto and highlighting potential constitutional issues. The Treasury's interim guidance can be relied upon immediately for 2025 tax returns due in 2026, and tax experts expect it to become permanent.
The new guidance removes a major roadblock to corporate Bitcoin adoption, leveling the playing field with traditional securities. Companies no longer have to worry about potential tax liabilities on unrealized gains, encouraging more businesses to invest in and hold Bitcoin. This could significantly impact the crypto market and its integration into the broader economy.
