Major Win for Crypto: Treasury to Exempt Bitcoin from CAMT

In a significant development for the cryptocurrency industry, the U.S. Treasury Department is reportedly preparing to exempt crypto holdings from the Corporate Alternative Minimum Tax (CAMT).

This move could save companies with substantial Bitcoin holdings, such as Strategy, billions of dollars. The CAMT, a 15% minimum tax on large corporations, would have previously forced companies to pay taxes on unrealized gains on their digital assets. This was due to accounting rules requiring mark-to-market valuations.

Strategy currently holds over 640,000 Bitcoin, valued at over $74 billion. Unrealized gains are estimated to be over $27 billion. Had the exemption not been granted, the company faced potential federal tax liabilities in the billions starting in 2026.

The Pushback and Rationale

The exemption follows strong opposition from companies like Strategy and Coinbase. In a joint letter to the Treasury, they argued that taxing unrealized gains:

• Creates unfair treatment compared to traditional assets.
• Could force asset sales to cover tax liabilities.
• Disadvantages U.S. firms against foreign competitors.
• Raises constitutional concerns about taxing "paper profits."

The Treasury Department issued Notice 2025-49, offering interim guidance on CAMT application. The notice included an “FVI Exclusion Option,” allowing corporations to exclude fair value measurement adjustments for assets like digital currencies.

The Senate Finance Committee held a hearing titled “Examining the Taxation of Digital Assets” on October 1, to discuss current tax rules and how they apply to digital assets.

Key Takeaways:

• The Treasury is expected to exempt crypto from CAMT.
• This prevents taxation on unrealized gains, potentially saving companies billions.
• The decision follows industry pushback and concerns over competitiveness.
• New guidance allows companies to exclude fair value adjustments for crypto assets.

This exemption aligns with the executive order on “Strengthening American Leadership in Digital Financial Technology,” that aims to protect economic liberty and technological innovation.