Crypto Treasury Firms Benefit from Limited IRS Guidance

What to Know:

• New IRS guidance alleviates tax pressure on companies with crypto holdings.
• Large corporations, including Digital Asset Treasury (DAT) companies, will primarily benefit.
• Interim guidance is applicable, and companies can rely on it for next year’s tax filing.

Ripple, a major player in the crypto market, along with other crypto-focused businesses, will find solace in the recent Internal Revenue Service (IRS) guidelines. These directives aim to ease the tax burdens on companies holding cryptocurrencies and other digital assets, albeit with some business-type restrictions.

Earlier this week, the IRS unveiled provisional guidelines stating that C Corporations — a specific kind of business — generating over $1 billion in revenue are no longer required to pay taxes on unrealized capital gains under the Corporate Alternative Minimum Tax. This change is a boon for companies such as Strategy (MSTR) and Mara Holdings (MARA), considering the substantial amount of Bitcoin these corporations hold on their balance sheets. Both businesses have expressed their expected benefit from the new guidance.

As a result of Treasury and IRS interim guidance issued yesterday, Strategy does not expect to be subject to the Corporate Alternate Minimum Tax (CAMT) due to unrealized gains on its bitcoin holdings. $MSTR https://t.co/DEgluG8oEN

— Michael Saylor (@saylor) October 1, 2025

Brett Cotler, a partner at the law firm Seward & Kissel, stated that this would primarily extend to larger corporations, including Digital Asset Treasury (DAT) companies. He explained that companies could face a tax liability without having the necessary cash due to crypto’s volatility, and would potentially need to liquidate assets for payment. The new proposal mitigates this issue by not requiring these assets’ recognition on a mark-to-market basis. It will undoubtedly assist the existing firms and likely benefit other non-DAT corporate entities holding crypto.

The corporate alternative minimum tax regime, which previously imposed a minimum tax on larger corporations, also applied to treasury asset values. These corporations would have had to pay taxes on such values, according to Cotler.

Not just crypto

Shehan Chandrasekera, head of tax strategy at CoinTracker, noted that companies with crypto assets are also under the same rules. He emphasized that it is not an issue exclusive to crypto, but any company generating roughly a billion dollars of revenue annually would be subject to it. The relation to crypto arises when marking up crypto, triggering unrealized gains.

Both Cotler and Chandrasekera asserted that the interim guidance is applicable, meaning companies can depend on it when filing taxes next year. Such interim guidance typically progresses to a proposed final rule before finalization. Although the IRS’s guidance this week isn’t finalized, it indicates the agency’s direction.

Companies won’t need to file until April of next year, with the possibility to extend until October. This extension allows the IRS time to finalize this guidance, even amidst the ongoing government shutdown, which has paused all non-essential work by federal employees.

In conclusion, while the IRS’s new guidance is not specifically tailored to crypto, it will significantly impact businesses holding crypto assets, such as Ripple, by easing their tax burdens. It is a positive step towards further institutional adoption of cryptocurrencies, reflecting a more accepting regulatory environment for the crypto market. The finalization of this guidance will be eagerly awaited by many in the crypto sector, marking another crucial milestone in the path towards mainstream acceptance of cryptocurrencies.

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