By Richard Rubin

The Treasury Department said late Tuesday that it would soften a proposed tax rule that could have forced Strategy to pay billions of dollars in taxes on the unrealized capital gains on its bitcoin holdings.

The potential tax liability was due to the corporate alternative minimum tax, or CAMT, the 15% minimum tax on large corporations' financial statement income that President Joe Biden signed into law in 2022. Until Tuesday's notice, rules for the CAMT would have included unrealized digital-asset gains in income while excluding unrealized gains on stocks.

Strategy, formerly known as Microstrategy, has transformed itself in part into a bet on bitcoin. It holds $73 billion worth of the cryptocurrency, and about $26 billion of that is unrealized gains, according to securities filings. The company has been warning investors about the potential tax liability and asked Treasury to prevent it.

The Treasury guidance also softened some proposed CAMT rules for shipping companies, regulated utilities and insurance companies. Companies have complained about CAMT's complexity and potential unintended consequences, and the Trump administration has been more receptive to those concerns than its Democratic predecessors.

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September 30, 2025 17:18 ET (21:18 GMT)

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