Strategy May Avoid Multi-Billion CAMT Liability After IRS and Treasury Clarify Treatment of Bitcoin Unrealized Gains

• CAMT exclusion clarified

• Strategy will follow IRS/Treasury guidance and does not expect CAMT liability from unrealized Bitcoin gains in 2026 and beyond.

• Strategy’s Bitcoin unrealized gain is nearly $28 billion on $47.4 billion invested (current valuation cited in company filings).

Strategy CAMT clarified: IRS/Treasury exclude unrealized digital-asset gains from CAMT calculations — learn what this means for corporate Bitcoin holders. Read on for details.

What is the impact of the CAMT clarification on Strategy?

Strategy CAMT clarification removes the need to include unrealized gains or losses on digital assets when determining liability for the 15% corporate alternative minimum tax (CAMT). Strategy now says it “no longer expects to become subject to CAMT due to unrealized gains on its Bitcoin holdings” for 2026 and beyond, per its SEC filing.

How did the IRS and Treasury change CAMT guidance for digital assets?

The IRS and Treasury issued a 71‑page guidance document stating firms are not required to factor unrealized gains or losses on digital assets into CAMT calculations. This clarification explicitly excludes mark‑to‑market changes on cryptocurrencies from the CAMT base for corporations.

Tax and market analysts, including TD Cowen (analyst Lance Vitzanza), said the guidance removes a significant potential overhang on Strategy’s stock and avoided a possible multi‑billion cash tax liability that could have begun in 2026.

Why does this matter for corporate Bitcoin holders?

Front-loading the effect: companies holding large Bitcoin positions were at risk of an unexpected CAMT liability as crypto appreciated. With the clarification, unrealized appreciation will not automatically trigger CAMT, improving cash‑tax planning and reducing potential forced liquidations or capital redeployments tied to tax needs.

How much unrealized gain does Strategy hold and what changed in market reaction?

Strategy has spent approximately $47.4 billion acquiring Bitcoin and currently carries an unrealized gain close to $28 billion based on its filings. Following the IRS/Treasury guidance and Strategy’s confirmation, Strategy shares rose about 5% in intraday trading; the stock has advanced roughly 10% over the past six months.

When did Strategy change its CAMT outlook and where was it disclosed?

Strategy disclosed the change in outlook in an SEC filing following the IRS and Treasury guidance. The company previously indicated in June that it expected CAMT liabilities; after the guidance, Strategy stated it “no longer expects to become subject to CAMT due to unrealized gains on its Bitcoin holdings.”

What did analysts and market data report?

TD Cowen analyst Lance Vitzanza said the IRS action removed a significant potential overhang, noting Strategy could have faced substantial cash tax liabilities if unrealized gains were included. Market data providers and financial news commentary reported a short‑term positive market reaction.

Frequently Asked Questions

Will this IRS guidance change how other corporations report Bitcoin?

This guidance sets a precedent: corporations holding digital assets should not include unrealized gains or losses in CAMT computations. Companies will continue reporting holdings per SEC and accounting standards and will reference the IRS/Treasury guidance for tax planning.

Does this remove all tax risk associated with corporate crypto holdings?

No. The clarification addresses CAMT treatment of unrealized gains. Corporations still face ordinary tax rules on realized gains, withholding regimes, state taxes, and evolving regulatory or legislative changes; firms should continue robust tax and compliance reviews.

Key Takeaways

• Immediate relief: The IRS/Treasury clarified that unrealized digital‑asset gains are excluded from CAMT, easing potential tax pressure on large holders.
• Strategy outlook: Strategy stated it no longer expects CAMT liability from unrealized Bitcoin gains in 2026 and beyond, per its SEC filing.
• Next steps for firms: Corporations should update tax models, maintain disclosure transparency, and monitor official guidance and accounting interpretations.

Conclusion

The IRS and Treasury clarification materially reduces the near‑term tax uncertainty for Strategy and other corporate Bitcoin holders by excluding unrealized gains from CAMT calculations. Companies should incorporate the guidance into tax planning and public disclosures while continuing to monitor rulemaking and accounting guidance. COINOTAG will update this report if further official guidance or company disclosures emerge.

By COINOTAG — Published: 2025-10-01 — Updated: 2025-10-01