In a series of moves that have largely flown under the radar, the Trump administration, through the U.S. Treasury and IRS, is methodically undermining a key tax reform designed to ensure the nation’s most profitable corporations pay their fair share. The latest regulations and temporary advice introduce fresh tax benefits, especially suiting big companies, private equity groups, and key figures in the crypto world.
Critics charge that these regulatory changes are gutting the 2022 Corporate Alternative Minimum Tax (CAMT) and will cost the federal government hundreds of billions in expected revenue. This all comes just months after the administration passed a $4 trillion tax cut package in July, which suggested that the administration was pursuing a two-pronged approach—legislative and regulatory—to cutting corporate tax burdens.
Defanging the ‘Billionaire Tax’
The law at the center of this battle is the Corporate Alternative Minimum Tax, or CAMT, which was passed in 2022. In simple terms, this law was designed to be a backstop. It required large corporations—those with average annual “book profits” (the number they report to shareholders) of over $1 billion—to pay at least a 15% tax.
This was intended to stop the notorious practice of a company reporting record-breaking profits to Wall Street while using a different set of books, full of deductions and credits, to report little or no profit to the IRS, resulting in a $0 tax bill. The Treasury and IRS, however, are now issuing new rules that critics say are riddled with loopholes, effectively creating off-ramps for the very companies the law was meant to target.
A Massive, Unspoken Win for Crypto
Perhaps the most significant new carve-out is a specific gift to the cryptocurrency industry. A major problem was brewing for crypto-holding companies. In late 2023, new accounting standards (FASB) required companies to report furniture “paper gains” on their digital asset holding like bitcoin in net income, regardless of whether or not the company ever sold the asset, this caused a logistical nightmare for massive corp holders such Strategy and Coinbase. The soaring value of their Bitcoin treasuries would create billions in “paper profits,” pushing them well over the CAMT’s $1 billion threshold and triggering a massive 15% tax bill on gains that only existed on a ledger.
The new Treasury guidance, issued quietly, solves this problem in a single stroke: It clarifies that these “unrealized gains on digital assets” do not count when calculating income for the 15% minimum tax.
Corporate Holders Breathe a Sigh of Relief
“Strategy,” the public company with the largest corporate Bitcoin treasury, had previously warned investors that it expected to be subject to the CAMT in 2026. Following the Treasury’s new guidance, the company stated in a public filing that it “no longer expects to be subject” to the tax.
This single regulatory change, which received almost no public debate, effectively saves crypto-heavy corporations billions of dollars, allowing them to benefit from the new accounting rules on their balance sheets without facing the tax consequences.
A ‘One-Two Punch’ With July’s Tax Cuts
This quiet regulatory relief is being viewed by analysts as the second part of a one-two punch that began with legislation this summer. On July 4, 2025, President Trump signed the “One Big Beautiful Bill Act,” a $4 trillion reconciliation package that, among other things, made the 2017 individual tax cuts permanent.
That bill was already aimed at helping large corporations by restoring R&D expensing and other business-friendly provisions, which were themselves in conflict with the 2022 minimum tax. The new Treasury rules are now finishing the job by using regulatory power to clear away the CAMT roadblocks that the July legislation didn’t fully address.
Fiscal Impact and Growing Concerns
While beneficiaries of the new rules are celebrating, budget watchdogs are raising alarms. The 2022 CAMT was projected to raise over $220 billion over a decade. Analysts now say that between the new legislation and these quiet regulatory carve-outs, a significant portion of that expected revenue is effectively gone.
For many, this represents a major expansion of the administration’s corporate-leaning tax policy. It raises serious concerns about the financial impact at a time of high deficits and raises concerns about the legitimacy of an agency using its rule-making authority to so thoroughly blunt a law enacted by Congress.
