The U.S. Internal Revenue Service has issued interim guidance that significantly alters the tax treatment of corporate-held digital assets under the Corporate Alternative Minimum Tax (CAMT) framework. In Notices 2025-46 and 2025-49 released on September 30, 2025, the IRS has provided transitional relief for companies holding cryptocurrencies and other digital assets. The new guidance allows corporations to exclude unrealized gains and losses on digital assets from CAMT calculations when these assets are accounted for at fair value. This policy shift addresses a critical industry concern where companies faced potential tax liabilities on paper profits from cryptocurrency holdings, even without actual asset sales. Under previous CAMT rules, corporations with three-year average annual financial statement income exceeding $1 billion were subject to taxation on unrealized gains resulting from fair value accounting requirements. The change follows significant industry pushback, including joint letters from MicroStrategy and Coinbase to the IRS in May, arguing that taxing unrealized gains could force companies to liquidate bitcoin holdings to meet tax obligations, potentially disadvantaging U.S. firms in global markets. Key implications of the policy adjustment include: Reduced Tax Burden and Cash Flow Pressure: Companies will no longer face tax liabilities on paper gains from cryptocurrency appreciation, eliminating the need to maintain cash reserves for potential tax payments on unrealized profits. Enhanced Market Stability: The clarification reduces regulatory uncertainty for cryptocurrency investors and may positively impact valuations of companies with significant digital asset holdings. Encouragement for Corporate Adoption: With greater tax predictability, companies may be more inclined to incorporate cryptocurrencies into their balance sheets as strategic reserve assets. However, the guidance remains interim rather than final regulations, creating some ongoing uncertainty. Potential risks include tax avoidance concerns if companies attempt to reclassify realized gains as unrealized profits, and questions about unequal treatment between digital and traditional assets. The policy evolution represents a significant step toward aligning cryptocurrency taxation with traditional tax principles that typically recognize income only upon realization. This development may help establish a more predictable and stable tax environment for digital assets while maintaining appropriate revenue safeguards for the government. Disclaimer: This analysis represents professional interpretation of recent tax developments and should not be considered as tax advice. Readers should consult qualified tax professionals regarding their specific circumstances.