Overview

• Notice 2025-49 introduces an FVI Exclusion Option that removes fair‑value crypto gains from CAMT calculations and offers a Hedge Coordination Option for certain hedges, with immediate reliance allowed.
• Strategy disclosed in an SEC filing that it will follow the guidance and no longer expects CAMT exposure tied to its Bitcoin holdings in 2026 and beyond.
• Strategy holds roughly 640,000 BTC with unrealized gains reported in the tens of billions of dollars, a risk analysts said could have forced large cash tax payments under prior assumptions.
• Bitcoin rallied above $117,000 and shares of major corporate holders, including Strategy and MARA, rose after the guidance clarified treatment of digital assets under CAMT.
• Treasury signaled it will issue revised proposed regulations reflecting the interim relief, while the Senate Finance Committee held a hearing on digital‑asset taxation featuring industry and policy experts.