The guidance follows heavy feedback on proposed regulations (REG-112129-23) published in September 2024. Those rules left corporations uncertain about how unrealized crypto gains would be treated under the CAMT framework.
By addressing this gap, Treasury and the IRS aim to reduce compliance costs and clarify how firms calculate their adjusted financial statement income (AFSI), the tax base for CAMT. Companies may immediately rely on this interim relief, with similar provisions expected in forthcoming regulations.
The CAMT, created by the 2022 Inflation Reduction Act, imposes a 15% minimum levy on corporations reporting at least $1 billion in average annual AFSI.
That calculation would have included unrealized digital asset gains without adjustments, potentially creating enormous paper tax liabilities for companies with large crypto holdings.
Before this guidance, analysts expected the company to fall under CAMT in 2026, exposing billions in potential liability on unrealized Bitcoin gains.
The new rules, however, would allow the company to exclude those unrealized crypto gains from AFSI.
As a result, Strategy no longer expects to face CAMT exposure linked to its $16 billion in Bitcoin holdings. That shift removes a major overhang on the company’s long-term strategy of holding Bitcoin as a reserve asset.
With more than 100 public firms holding over 1 million BTC, the ruling could strengthen Bitcoin’s role as a corporate reserve instrument.
Considering this, Bitcoin advocates welcomed the move as validation for corporate treasuries.
