New IRS Guidance Frees Strategy From 15% Burden on Unrealized Bitcoin Gains
Tax policy adjustments are reshaping corporate earnings expectations for firms with large cryptocurrency reserves. Strategy Inc. (Nasdaq: MSTR) announced on Oct. 1 that interim guidance from the U.S. Department of the Treasury and the Internal Revenue Service (IRS) allows companies to disregard unrealized digital asset gains and losses when calculating adjusted financial statement income (AFSI) for corporate alternative minimum tax (CAMT) purposes. The change removes a potential 15% minimum tax burden that Strategy had previously projected.
In its latest disclosure, Strategy highlighted the relief provided by the interim guidance: “Pursuant to the Interim Guidance, the company plans to exclude its unrealized gains and losses from the calculation of its AFSI for purposes of determining whether it is subject to CAMT.” Strategy added:
As a result, the company no longer expects to become subject to CAMT due to unrealized gains on its bitcoin holdings.
The company noted that the Treasury and IRS intend to issue revised regulations, which could alter the treatment of digital assets and leave some uncertainty over future tax exposure.
As of Sept. 28, Strategy had acquired 640,031 BTC for $47.35 billion at $73,983 per bitcoin. For the second quarter ended June 30, 2025, Strategy reported an unrealized fair value gain on digital assets of $14 billion.
The company explained how accounting changes had created the expectation of additional tax obligations. It previously disclosed that, given the magnitude of its unrealized gain on bitcoin as of June 30, 2025, it expected to become subject to CAMT “in the tax years beginning in 2026 and beyond.”
These concerns stemmed from new accounting standards requiring bitcoin holdings to be measured at fair value, with changes reflected in net income each period. Rising bitcoin prices meant large unrealized gains were recorded, which inflated AFSI above the $1 billion threshold used to determine CAMT applicability. The interim guidance reverses this effect by excluding such unrealized digital asset gains, removing the risk that Strategy will fall under CAMT’s scope.
