How CFOs Should Evaluate Corporate Bitcoin Treasury Allocations: Lessons from Steak ’n Shake’s $10M Bet

Published at 2026-01-18 16:14:46

Summary

Corporate treasuries are increasingly allocating to BTC for reasons that include inflation hedging, balance-sheet diversification, and return seeking. Steak ’n Shake’s recent $10M purchase is a clear, small-cap case study of that trend.

Before executing a treasury buy, CFOs must weigh accounting treatment (historically as an intangible under US GAAP), tax consequences on disposition, custody and counterparty risk, and board-level governance.

This article provides a structured checklist and pragmatic controls — from policy language and accounting sign-off to custody selection and disclosure planning — so finance leaders can move deliberately rather than react to headline-driven pressure.

Executive summary

Corporate interest in allocating cash to BTC is accelerating beyond the blue-chip headline cases. Steak ’n Shake’s $10 million purchase this year is a useful micro-case — not because the amount is large versus corporate treasuries, but because it illustrates the logic and practical hurdles smaller public and private firms face when adding BTC to the balance sheet. For CFOs and boards, the decision is as much about governance, accounting and tax mechanics as it is about the macro thesis.

Why companies are considering BTC as a treasury asset

Institutional drivers are straightforward but nuanced. CFOs commonly cite three overlapping motivations:

Inflation hedge / store of value — With persistent inflation concerns, some treasurers view BTC as an alternative to cash and short-duration instruments.
Balance-sheet diversification — Allocating a portion of cash to BTC can reduce correlation to traditional assets and create asymmetric upside.
Strategic treasury returns — When cash yields are near zero, corporates look for assets with better long-term expected returns, accepting volatility in the short term.

For many treasurers, Bitcoin remains the primary market bellwether and the most liquid on-chain asset to consider for corporate allocations. That said, motivations must be reconciled with liquidity needs, funding covenants, and stakeholder expectations.

Steak ’n Shake: a small but informative case study

Regional restaurant operator Steak ’n Shake disclosed a $10 million BTC purchase as part of a strategic reserve move — a choice covered in mainstream reporting and useful as an example of how smaller public companies structure a first treasury allocation. News reports framed the buy as emblematic of growing corporate adoption: see the company announcement and contemporaneous coverage to understand timing and phrasing (Steak ’n Shake increases Bitcoin exposure and secondary reporting at CryptoNews).

The key takeaway: the public narrative often focuses on headline dollar amounts. For a CFO, the more useful questions are about the policy foundation that justified the allocation and the controls used to execute and report the position.

Accounting and reporting considerations

Accounting treatment materially affects the decision. Under current US GAAP practice, most companies that hold BTC classify it as an intangible asset (ASC 350). That classification has three practical implications:

Impairment accounting — Downward value changes generally require immediate impairment recognition in earnings; there is no upward remeasurement to restore previously recognized impairments.
Earnings volatility — Because recoveries in market value are not recognized until a sale occurs, reported net income can understate economic recovery in rallying markets.
Disclosure burden — Companies need robust disclosure around valuation, controls, custodial arrangements, and risk management.

IFRS frameworks usually treat crypto-assets as intangible assets as well, though local differences exist. CFOs should consult external auditors early: regardless of jurisdiction, auditors will want documentation of policies, reconciliations, custody confirmations, and any fair-value procedures if management elects an alternative accounting treatment where permitted.

Governance elements that auditors and boards will expect

Formal treasury policy with explicit rationale, target allocation ranges, maximum single-asset exposure, and authorization thresholds.
Board-level approval and periodic reporting cadence (monthly P&L/mark-to-market and quarterly strategic reviews).
Segregation of duties across investment decision, execution, custody management, and accounting.
Independent custody or insured custodial agreement with proof of controls and certifications.
External audit and valuation methodology documentation.

Tax and regulatory pitfalls to avoid

Tax treatment varies by jurisdiction, but common corporate issues include:

Realization events — For tax purposes, gains/losses are typically recognized on disposal; planning for potential tax liabilities on future disposals is essential.
Basis tracking — Accurate cost-basis and lot-level tracking must be maintained for correct tax reporting.
Indirect tax and VAT considerations — Some jurisdictions treat crypto transfers differently for indirect tax; get local tax counsel.
Sanctions and AML screening — Treasury counterparties and custodians must perform sanctions and anti-money-laundering checks; finance teams should require OFAC/SDN screening as standard.
Securities law and disclosures — While BTC is generally viewed as a commodity rather than a security, public companies must ensure their disclosures meet securities-regulator expectations for material financial information.

Engage tax and legal counsel before executing any material trade. A surprise taxable gain when the company needs cash for operations is a solvency risk many boards ignore until it’s too late.

A practical CFO checklist before executing a BTC treasury buy

Below is a concise checklist to use as a governance template. Each item should be a documented line in the company’s treasury or investment policy.

Define strategic objective — Inflation hedge, diversification, or strategic holding? Tie the objective to measurable KPIs and review periods.
Set allocation limits — Specify target range (e.g., 0.5–5% of liquid assets for conservative profiles; greater only with board approval) and a hard maximum.
Obtain board approval — Present the thesis, accounting impacts, tax plan, custodial options, and stress-test scenarios.
Consult auditors and tax counsel — Confirm accounting classification, impairment mechanics, and tax treatment in relevant jurisdictions.
Select custody solution — Prefer regulated, insured custodians or multi-signature setups with enterprise-grade controls; validate insurance limits and exclusions.
Vendor and counterparty due diligence — Financial strength, SOC reports, disaster recovery, insurance certificates, and legal agreements.
Execution plan — Decide on DCA (dollar-cost averaging) vs lump-sum, trading counterparties, and limits to avoid market impact.
Operational controls — Reconciliation cadence, access controls, approval workflows, key rotation and custody drills.
Disclosure and investor communications plan — Pre-approved messaging for press, SEC filings (if public), and internal stakeholders.
Exit and liquidity planning — Define thresholds and triggers for partial or full liquidations, and pre-negotiate liquidity providers if needed.

Example allocation frameworks

Conservative: 0.5–1.5% of cash and short-term investments; limited to tactical hedge purposes.
Balanced: 1–5% with formal rebalancing triggers and quarterly review.
Aggressive: >5% requires robust governance, dedicated crypto risk management, and board-level oversight.

Adjust frameworks with scenario modeling: stress-test the balance sheet under BTC drawdowns of 30–80% and evaluate covenant impacts.

Execution best practices and post-investment controls

Stagger buys to reduce timing risk — Dollar-cost averaging reduces the odds of poor market-timing outcomes.
Confirm settlement and custody mechanics in writing — Reconcile custodial statements with general ledger monthly.
Insurance and recovery testing — Confirm coverage for theft, custody failure, and key compromise; conduct periodic recovery simulations.
Maintain transparent audit trails — Every trade, fiat on/off ramps, and custody transfer should be documented and auditable.
Coordinate earnings and tax provisioning — Reserve for potential tax on realized gains; explain impairment mechanics to investors to set expectations.

Final thoughts for boards and CFOs

Steak ’n Shake’s $10M purchase is a useful reminder that corporate BTC adoption is no longer limited to marquee software firms. The decision to add BTC to the treasury should be treated as a strategic finance action — not a marketing stunt. When undertaken properly, a modest, well-governed BTC allocation can serve diversification and hedging objectives; done poorly, it can create accounting volatility, tax surprises, and operational risk.

CFOs should proceed with a disciplined policy, early auditor and tax engagement, and clear governance. For teams exploring crypto instruments as part of a broader treasury toolkit, consider platforms and vendors that make custody, execution, and tax reporting easier — including how Bitlet.app and other boutique providers integrate custody and P2P functionality into corporate workflows.

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