The CAMT, enacted in 2022, imposes a 15% minimum tax on corporations earning over $1 billion in annual income, based on their financial statement income rather than taxable income.

Under Financial Accounting Standards Board (FASB) rules, companies must “mark-to-market” cryptocurrency holdings on their books, recording paper gains and losses as if the assets were sold at current prices.

For firms like Strategy, who aim to hold one trillion-dollars worth of Bitcoin, the distinction could have translated into tens of billions in annual tax bills on unrealized profits.