Bitcoin Escapes CAMT Tax as Treasury Issues New Guidance

• Treasury exempts Bitcoin from CAMT, removing tax on unrealized corporate crypto gains.
• Strategy avoids billions in liabilities, holding 640,000 Bitcoin with $27B paper profits.
• IRS issues relief guidance as Senate prepares hearing on broader crypto tax rules.

The U.S. Treasury has moved to exempt Bitcoin and other cryptocurrencies from the 15% Corporate Alternative Minimum Tax (CAMT), a rule originally enacted under the Inflation Reduction Act of 2022. The change removes the risk of taxing unrealized gains on digital assets, a measure that could have cost crypto-heavy corporations billions in federal liabilities. Companies such as Strategy and Coinbase had warned that including paper profits in tax calculations would create unfair burdens and force asset sales. The decision is expected to reshape how corporate America approaches large-scale digital asset holdings.

Treasury issues Notice 2025-49

Corporations will be permitted to exclude unrealized gains on Bitcoin and other digital assets to CAMT calculations, under guidance on such assets issued by the Treasury on September 29 under Notice 2025-49. The exemption, which is also known as the FVI Exclusion Option, allows the firms to neglect fair value accounting adjustments of digital assets, unless they are sold. Another alternative of Hedge Coordination Option has also been proposed to bring CAMT rules into consistency with hedging practices.

The new measures, they said, will be integrated into new regulations that will be released later in the year. The move is the culmination of months of lobbying on the part of Strategy and Coinbase, who contended that taxing paper gains would put U.S. companies in an unfair competitive position against foreign firms, and would also create constitutional challenges.

Strategy is currently the owner of over 640,000 Bitcoin worth over $74 billion, and $27 billion in unrealized gains. In the absence of the exemption, the company would have had multibillion-dollar CAMT liabilities beginning in 2026. The action of the Treasury also complies with Executive order 14178, Strengthening American Leadership in Digital Financial Technology, which stipulates the need to support the U.S. competitiveness in the digital asset market.

IRS and Senate actions on crypto taxation

The announcement by the Treasury was accompanied by temporary regulations by the Internal Revenue Service in Notice 2025-46 that explained how to treat corporation transactions, troubled companies and consolidated groups under CAMT. Both of these notices seek to minimize compliance requirements until final regulations are published.

The following day, the U.S. Senate Finance Committee announced a hearing on Wednesday titled, “Examining the Taxation of Digital Assets. Chair of the Committee, Mike Crapo, will hold the session, which will include the testimony of Coinbase vice president of tax Lawrence Zlatkin and Coin Center policy director Jason Somensatto. It is anticipated that legislators will debate how digital assets should be taxed in the current tax systems and whether its taxation should go beyond the CAMT relief.

It was observed that the exemption would give more incentives to corporations to put Bitcoin in their balance sheets without fear of taxing unrealized revenue. Simultaneously, regulatory hearings are an indicator that the taxation of digital assets will continue to be a developing problem in Congress and federal agencies.