TLDR:
- Treasury and IRS interim guidance allow Strategy to exclude unrealized Bitcoin gains from CAMT liability.
- Strategy recently bought 196 BTC, bringing total Bitcoin holdings to 640,031 coins.
- The average cost basis of Strategy’s Bitcoin vault is approximately $73,983 per BTC.
- Michael Saylor plans to build Strategy’s Bitcoin treasury toward a $1 trillion asset pile.
Something has changed in crypto tax policy. Strategy’s CEO, Michael Saylor, says new guidance from the U.S. Treasury and IRS means his company does not expect to owe the corporate alternative minimum tax (CAMT) on unrealized Bitcoin gains.
That shift removes a major uncertainty over how Strategy reports its massive Bitcoin holdings. The move arrives as Strategy continues to stack crypto, now holding over 640,000 BTC and reaffirms its ambition to build a $1 trillion Bitcoin treasury.
Below is what this means and how it connects to Strategy’s broader crypto strategy.
What the CAMT Update Means for Strategy and Crypto
Michael Saylor tweeted that because of Treasury and IRS interim guidance, Strategy
“does not expect to be subject to the Corporate Alternate Minimum Tax (CAMT) due to unrealized gains on its Bitcoin holdings.”
In simple terms: gains on Bitcoin that the company hasn’t sold won’t count toward the extra tax calculation.
That’s a big relief. Previously, Strategy had disclosed that unrealized gains could trigger CAMT liability in future years. The new rules allow corporations to exclude unrealized gains and losses in calculating their adjusted financial statement income for CAMT purposes.
The IRS and Treasury released interim rules (Notice 2025-46 and 2025-49) on September 30 to clarify many CAMT issues. Among those clarifications: how fair-value accounting and mark-to-market adjustments apply. Under this guidance, Strategy expects to be exempt from CAMT on its crypto holdings.
Market reaction was swift. Strategy’s stock (MSTR) ticked higher after the news, reflecting that investors see one less tax headwind. The new guidance reduces a structural risk for companies holding Bitcoin.
Strategy’s Bitcoin Accumulation and the $1 Trillion Ambition
According to an earlier report by Blockonomi, Strategy disclosed it added 196 BTC, about $22.1 million worth, in its latest acquisition. With that purchase, it now holds 640,031 BTC in total. The average cost basis remains relatively low (about $73,983 per BTC), meaning the bulk of the position sits in paper profit.
Saylor has publicly laid out a grand ambition: to amass a $1 trillion Bitcoin treasury. He refers to Bitcoin as “digital energy, property, and capital” in cyberspace, and believes Strategy and other firms can eventually reach that scale.
That goal is audacious. To get there, Strategy would need to keep acquiring Bitcoin aggressively over many years. The new CAMT clarity helps by reducing a tax overhang that might otherwise slow accumulation.
Still, the company’s approach draws scrutiny. Some argue that its dependence on capital markets to fund these purchases introduces dilution risk. But with the CAMT question largely resolved, one major barrier to its growth path looks clearer
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