Each 10 MW subdivision inside BrightEloy is an active Bitcoin mining business with its own LLC, its own LPs, its own equity stack, and its own depreciation. You earn a targeted 4 to 6% annual yield paid in Bitcoin, on top of pass-through bonus depreciation. Not paper. An operating business you actually own.
BrightEloy is not a fund. It is not a syndication of someone else's deal. Each sub-LLC is a fully formed, active Bitcoin mining business: it runs real equipment powered by on-site Arizona solar, produces Bitcoin from day one, and qualifies for the full stack of federal energy tax benefits available to operating partners under current law.
The role of a limited partner here is to participate as an active owner. Because Bitcoin mining is an active trade or business (solar generation is passive), the depreciation and losses are positioned to offset active, ordinary income, not just passive income. Owners also receive a targeted cash yield, paid in Bitcoin. The structure has been validated by independent counsel and accounting (Novogradac, Avisen Legal).
"Real business, real depreciation, real Bitcoin. The LP runs a mining operation. The operation runs on Arizona sun."
The BrightEloy platform decomposes into 30 sub-LLCs (BS1 through BS30), each one a 10 MW operating business. LPs participate in a single sub-LLC. Every sub-LLC is identical in structure and economics.
All figures from BSF Master Proforma v4.7 (June 2026). Subject to qualification and execution of definitive partnership documents.
The structure was designed around the federal energy tax provisions currently available to operating partners in qualified renewable projects.
Bitcoin mining is an active trade or business; solar generation is passive. With material participation, the bonus depreciation and operating losses are positioned to offset active, ordinary income, not just passive income, a materially more valuable shelter for most owners. The updated tax research and market analysis reflect this active-business treatment.
~$226M gross ITC ($203.4M monetized at 90%), recognized as megawatts are placed in service. A project-level credit, secured with PSI; it does not transfer with the land. Available through 2033 under current law.
100% first-year bonus depreciation, restored permanently in July 2025 under OBBBA. Passes through to LPs.
Direct transferability of energy credits, supporting flexible monetization of the ITC at the sub-LLC or platform level.
Tax position validated by Novogradac and Avisen Legal. Counsel engagement and legal opinion available to qualified LPs on request.
This page describes the structural and tax design of the LP opportunity. It is not tax advice. Every prospective LP should consult their own tax counsel before participating.
The detailed LP deck, the master proforma, the tax ROI calculator, and the draft partnership term sheet are available on request. We will reach out within two business days to start the qualification conversation.
