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Treasury and IRS Exclude Unrealized Crypto Gains From 15% Corporate Minimum Tax

Interim notices take effect immediately, with final regulations and congressional review pending.

Strategy & MSTR - Could tax relief fuel its Bitcoin holdings?
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Strategy avoids tax hit on Bitcoin after new IRS guidance
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Overview

  • Notices 2025-46 and 2025-49 clarify CAMT calculations and add an FVI Exclusion Option and a Hedge Coordination Option to address fair‑value adjustments and hedges.
  • Strategy said in an SEC filing that it no longer expects CAMT exposure from unrealized Bitcoin gains and plans to rely on the guidance.
  • Bitcoin prices jumped toward $117,000 and shares of Strategy and other crypto‑linked equities rose following the announcement.
  • The Senate Finance Committee held a hearing on digital‑asset taxation as the policy was released, featuring industry and tax experts.
  • The relief is interim and geared to large C corporations subject to CAMT, easing concerns about paying taxes on paper gains that could force asset sales.