Michael Saylor’s Strategy Gains Bitcoin Tax Shelter Under Treasury’s Latest IRS Guidance

The US Treasury Department announced adjustments to proposed tax regulations on Tuesday that remove a significant burden from Strategy's extensive Bitcoin portfolio. This move addresses concerns over the corporate alternative minimum tax, or CAMT, which risked imposing billions in liabilities on unrealized gains from digital assets. Strategy, the enterprise software firm once known as MicroStrategy, stands to benefit directly as the guidance excludes such gains from calculations that determine tax exposure.

Enacted as part of the 2022 Inflation Reduction Act, the CAMT establishes a 15% minimum tax on adjusted financial statement income for corporations with average annual income exceeding one billion dollars over three years. Earlier drafts of the rules treated unrealized appreciation in cryptocurrencies differently from traditional assets like stocks, potentially capturing Bitcoin's price surges in taxable income. Treasury officials confirmed the revisions in discussions with the Wall Street Journal, signaling a shift toward equitable treatment across asset classes.

Strategy's Evolution as a Bitcoin Powerhouse

Strategy has positioned itself as a leading corporate advocate for Bitcoin adoption since 2020, accumulating holdings that now define much of its market identity. As of late September 2025, the company owns 640,031 Bitcoins, acquired at an average price of $73,983 per BTC, with the portfolio valued at approximately $74.67 billion based on prevailing market prices. This stash represents a strategic pivot under Michael Saylor, who views the cryptocurrency as a store of value compared to cash reserves.

The firm's disclosures highlight how Bitcoin's volatility has amplified both opportunities and risks, including the specter of CAMT-related taxes. Strategy repeatedly flagged this issue in investor communications, estimating potential hits to profitability if unrealized gains triggered the minimum tax starting in 2026. By lobbying Treasury for clarity, the company sought to safeguard its treasury approach, which has drawn imitators among other public firms exploring crypto reserves.

Treasury's interim guidance, issued jointly with the Internal Revenue Service on September 30, 2025, provides immediate relief while final regulations take shape. It directs corporations to disregard unrealized gains and losses on digital assets when computing adjusted financial statement income for CAMT purposes. This clarification aligns treatment of cryptocurrencies with equities, addressing a key asymmetry that drew criticism from affected businesses.

The adjustments extend beyond crypto, offering concessions to sectors like shipping, utilities, and insurance that had raised alarms about CAMT's operational impacts. Treasury's responsiveness reflects ongoing dialogue with stakeholders since the tax's inception, aiming to balance revenue goals with practical enforcement. For the broader crypto industry, the change fosters confidence in long-term holding strategies, potentially encouraging more institutional involvement without the overhang of unexpected tax events.

Strategy wasted no time in responding, with Saylor sharing the company's official stance early Wednesday. The firm filed a Form 8-K with the Securities and Exchange Commission, affirming that the guidance eliminates CAMT applicability to its Bitcoin gains. This development arrives at a pivotal moment, as Bitcoin trades near all-time highs and corporate treasuries increasingly diversify into the asset.