01—Abstract
Summary
Summary of the 8-K filed October 1, 2025. Cited figures are marked; the original filing is the authoritative source.
Strategy Inc filed an 8-K on October 1, 2025 to report two items under Item 8.01 (Other Events) related to U.S. tax treatment of its bitcoin holdings.
On September 30, 2025, the Treasury and IRS issued interim guidance clarifying that a corporation may disregard unrealized gains and losses on digital asset holdings when computing adjusted financial statement income (AFSI) for determining whether it is subject to the 15%a corporate alternative minimum tax (CAMT) under the Inflation Reduction Act of 2022. The Treasury and IRS also intend to issue revised proposed regulations similar to this interim guidance. The company explained that it adopted ASU 2023-08 on January 1, 2025, which requires it to measure bitcoin holdings at fair value, with gains and losses recognized in net income each reporting period.
It had previously disclosed that, given the magnitude of its unrealized digital asset gain as of June 30, 2025, it expected to become subject to CAMT beginning in tax years 2026 and later. Because it plans to exclude unrealized gains and losses on its bitcoin holdings from AFSI under the interim guidance, Strategy no longer expects to become subject to CAMT due to unrealized gains on its bitcoin holdings. For investors, this removes a previously anticipated future cash tax obligation tied to bitcoin valuation changes.
02—Key points
Key Highlights
- On September 30, 2025, Treasury and IRS issued interim guidance allowing corporations to disregard unrealized gains and losses on digital asset holdings when computing AFSI for the 15% CAMT.
- Treasury and IRS intend to issue revised proposed regulations similar to the interim guidance.
- Strategy adopted ASU 2023-08 on January 1, 2025, requiring its bitcoin holdings to be measured at fair value with gains and losses recognized in net income each period.
- Strategy had previously expected to become subject to CAMT in tax years beginning in 2026 and beyond, given the magnitude of its unrealized digital asset gain as of June 30, 2025.
- Under the interim guidance, Strategy plans to exclude unrealized bitcoin gains and losses from its AFSI calculation.
- As a result, Strategy no longer expects to become subject to CAMT due to unrealized gains on its bitcoin holdings.
03—Questions
Frequently Asked Questions
What is the CAMT and why did it matter to Strategy?
The 15% corporate alternative minimum tax under the Inflation Reduction Act applies to corporations whose average annual adjusted financial statement income (AFSI) exceeds $1 billion over a consecutive three-tax-year period, under the proposed regulations described in the filing. Because ASU 2023-08 requires bitcoin gains to flow through net income, Strategy had expected its large unrealized bitcoin gains to push it into CAMT starting in 2026.
What did the September 30, 2025 interim guidance change?
The interim guidance clarifies that a corporation may disregard unrealized gains and losses on its digital asset holdings when computing AFSI for CAMT purposes. The Treasury and IRS also intend to issue revised proposed regulations similar to this guidance.
Does this mean Strategy will pay no CAMT in the future?
The filing states that Strategy no longer expects to become subject to CAMT due to unrealized gains on its bitcoin holdings. It does not address other potential sources of CAMT liability.
What accounting change drove the original CAMT exposure?
Strategy adopted ASU 2023-08 on January 1, 2025, which requires it to measure its bitcoin holdings at fair value in its statement of financial position, with changes in fair value recognized in net income each reporting period.
04—Continue