Senate Schedules Cryptocurrency Tax Hearing Following Treasury Relief Announcement
The US Treasury Department and Internal Revenue Service issued interim guidance on Tuesday easing corporate cryptocurrency tax rules. According to Cointelegraph, Notice 2025-46 and Notice 2025-49 provide clarity on the Corporate Alternative Minimum Tax. The guidance allows digital asset companies to exclude unrealized gains and losses on crypto holdings from CAMT income calculations.
The CAMT imposes a 15% minimum tax on financial statement income of large corporations. Congress passed this provision under the Inflation Reduction Act of 2022. The law targets companies earning over $1 billion annually. Notice 2025-49 specifically addresses amendments to Adjusted Financial Statement Income. Companies can now disregard fair value measurement adjustments for digital assets marked to market on financial statements.
The US Senate Finance Committee scheduled a hearing for Wednesday on digital asset taxation. Committee Chair Mike Crapo will lead the session. Coinbase vice president of tax Lawrence Zlatkin and Coin Center policy director Jason Somensatto will participate.
Impact on Corporate Bitcoin Holdings
The Treasury guidance directly affects companies with substantial cryptocurrency positions. Cryptonews reports that Strategy currently holds approximately 640,031 Bitcoin valued at over $74 billion. The company recorded unrealized gains exceeding $27 billion. Without this relief, Strategy faced potential federal tax liabilities estimated in the billions starting in 2026.
The accounting treatment created tax exposure for firms holding digital assets as fair value investments. Financial Accounting Standards Board rules require companies to record Bitcoin holdings at mark-to-market prices. This accounting method would have triggered CAMT obligations on paper gains never converted to cash. We previously reported that Strategy launched a $2 billion convertible note offering for general corporate purposes including Bitcoin acquisition in February 2025.
Companies holding crypto assets for treasury purposes benefit most from this interim guidance. The relief removes a compliance burden that would have forced asset sales to cover tax payments. Strategy and Coinbase submitted formal comments to the IRS in January 2025 requesting unrealized gain exclusions.
Broader Implications for Digital Asset Adoption
The Treasury decision addresses competitive concerns raised by cryptocurrency industry leaders. Cryptonews notes the exemption maintains tax parity between domestic and foreign corporations. International financial reporting standards do not require mark-to-market accounting for crypto assets. This created disadvantages for US companies subject to Generally Accepted Accounting Principles compared to international competitors.
The interim guidance follows the White House Digital Asset Working Group's July recommendations. Those recommendations urged lawmakers to recognize crypto as a new asset class. The working group suggested adjusting tax rules for securities and commodities to apply to digital assets. The Senate hearing Wednesday will examine broader cryptocurrency taxation policies beyond CAMT relief.
Industry observers view this development as reducing regulatory uncertainty for corporate crypto adoption. The Treasury stated it plans to issue revised proposed regulations incorporating these new rules. No section of proposed or forthcoming regulations will apply to taxable years beginning before final regulations publish in the Federal Register. Senator Cynthia Lummis praised the guidance, stating it addresses threats to unrealized Bitcoin gains and supports American innovation in the digital asset sector.
