Bullish
IRS Tax Relief for Crypto Treasury Firms: Limited Guidance Benefits Bitcoin Holdings
03.10.2025 20:21
New IRS guidance provides significant tax relief for corporations holding cryptocurrencies, though the scope remains limited to specific business types. The Internal Revenue Service announced that C Corporations generating over $1 billion annually are exempt from paying taxes on unrealized capital gains under the Corporate Alternative Minimum Tax. This development particularly benefits major crypto treasury firms like MicroStrategy (MSTR) and Marathon Digital Holdings (MARA), given their substantial Bitcoin (BTC) reserves. Both companies confirmed they would gain advantages from this interim guidance.
According to Brett Cotler of Seward & Kissel law firm, this relief primarily applies to larger corporations, including Digital Asset Treasury (DAT) companies. "Cryptocurrency volatility often creates tax liabilities without corresponding cash flow, forcing asset liquidation. This proposal eliminates mark-to-market recognition for these assets, providing crucial relief," Cotler explained.
The corporate alternative minimum tax regime targets specific corporation types, previously requiring tax payments on treasury asset valuations. While not crypto-specific, the guidance significantly impacts crypto-heavy corporations due to unrealized gains from cryptocurrency holdings.
Tax experts confirm this interim guidance remains applicable for upcoming tax filings. Companies can rely on these provisions for April filings, with potential extensions until October, allowing time for IRS finalization despite current government operational challenges.