Strategy Avoids $27B Tax Burden as U.S. Eases Crypto Rules
Strategy, a company with a substantial Bitcoin portfolio valued at approximately $74 billion, has been relieved of a potential $27 billion tax burden. Chairman Michael Saylor announced that the company will not be subject to the Corporate Alternative Minimum Tax (CAMT) due to unrealized gains on its Bitcoin holdings.
The relief comes courtesy of interim guidance issued by the U.S. Department of the Treasury and the IRS in September 2025. This guidance, Notice 2025-49 and Notice 2025-46, provides an 'FVI Exclusion Option' allowing corporations to ignore unrealized gains and losses on digital assets when calculating CAMT. This change addresses a significant concern for companies holding crypto, as accounting rules require them to report their crypto holdings at current Bitcoin price on financial statements, even if they never sell.
The new guidance also helps to level the tax playing field for U.S. companies holding crypto internationally. Under the old interpretation, companies would owe 15% tax on paper profits from Bitcoin price increases, despite having no actual cash from sales. This created a competitive disadvantage for U.S. firms compared to their international counterparts. Strategy and Coinbase had previously argued against taxing paper profits on Bitcoin in a joint letter to the Treasury in May 2025.
The Senate Finance Committee is currently examining crypto taxation more broadly, with hearings held on October 1, 2025. The new guidance removes a major roadblock to corporate Bitcoin adoption by addressing tax concerns related to Bitcoin price fluctuations. This change comes as a result of the Inflation Reduction Act of 2022, which introduced the CAMT for corporations making over $1 billion annually.
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