Overview
- Treasury issued Notice 2025-49, which excludes unrealized gains on digital assets from the Corporate Alternative Minimum Tax and introduces an FVI Exclusion Option to disregard fair value adjustments in CAMT calculations.
- Strategy said it will owe no CAMT on its Bitcoin holdings following the clarification; the company holds about 640,031 BTC valued near $74 billion with roughly $27 billion in unrealized gains.
- CAMT, enacted in 2022, applies a 15% minimum tax to corporations with over $1 billion in income based on financial-statement figures, while unrealized gains on equities were already outside its scope.
- Strategy and Coinbase pressed for the change in a May letter arguing that taxing unrealized crypto gains could force asset sales, disadvantage U.S. firms, and create unfair treatment versus stocks and bonds.
- The Senate Finance Committee is holding a hearing on digital-asset taxation today, and Treasury signaled it intends to follow the notice with revised proposed regulations.