New Era Energy & Digital · TCDC
Who must fund TCDC, which taxpayer can use each deduction, and what value remains for the original shareholders?
Frozen taxpayer-specific tax, ownership and financing comparisons. The selected package is conditionally feasible, with no verified executed financing package. This browser selects captured results. The editable workbook provides the calculations.
No verified executable project package
Modeled feasibility does not establish committed capital. Current unrestricted cash, amended Macquarie obligations, legal ownership allocations and project consents remain incompletely verified.
$6.6825
Value retained per original share at the frozen valuation date
The selected static financing case assumes future outside common capital, priced public issuance, LC replacement and lifecycle funding. It is the best passing E package within the declared grid, not a global optimum or a current share-price forecast. F timing and G policy cases change additional assumptions.
The principal tax case has no independently verified cost-segregation allocation and no blanket data-center building expensing. Partnership loss basis, interest restrictions, owner tax capacity and disposal tax determine whether a deduction becomes cash. Zero eligible energy credits are assigned to the actual fixed design.
No verified executable funded project package; discretionary construction remains financing-gated
The October 8 valuation date and physical source inputs are preserved. Statutory research extends through October 11, 2026 Pacific; October 9–11 filing coverage is not exhaustive. This release does not roll current cash, debt or shares forward to October 12.
C re-underwrites direct leasing with legacy tax. D keeps C's contractual financing fixed and substitutes pre-bill or current-law tax treatment. Both displayed D cases fail funding; their diagnostic calculations are not feasible shareholder values. Removing a developer does not remove outside financial capital or replacement services.
E re-underwrites debt and ownership under current-law tax. F separately tests financing-enabled timing. G changes specified policy transmission channels. A preserves v2.6 reference captures. The ten displayed captures include eight live workbook selectors and two frozen A references; the downloadable review and register describe the full search and sensitivities.
Ten frozen comparisons: eight active workbook selectors and two preserved v2.6 references. The browser selects captured outputs; it does not run the financial engine. Both fixed-C D tax cases and both Phase 1-only C/E captures remain unfunded.
Conditional value retained per original share
$6.6825
Conditional economically feasible
A conditional model output at the October 8, 2026 valuation date. It is not a stock-price forecast or an executable financing commitment.
Conditional modeling assumption
Every dated funding need and priced claimant must pass.
Complete economic funding and provider tests
PassConditional dated cash, capital-provider and covenant tests pass. Execution evidence remains separate.
P1 facility tests
PassEligibility, debt draws, required coverage and legal maturity are tested under the captured terms.
P2 facility tests
PassEligibility, debt draws, required coverage and legal maturity are tested under the captured terms.
Dated HoldCo funding
PassPublic issuance, restricted cash, owner tax and all dated obligations must reconcile.
Modeled acceptance, capacity and consent are separate from verified commitments.
Executed project debt and equity commitments
UnverifiedThe research cases are uncommitted; a mathematical pass does not establish drawable capital.
Binding tenant rent and credit support
UnverifiedLease, tenant credit, completion obligations and enforceable lender assignments are assumptions requiring documentation.
Macquarie priority and senior-lender consent
UnverifiedMacquarie first-lien subordination/release and intercreditor permissions are assumed, not verified.
Reconciled current unrestricted cash and amended payoff
UnresolvedLatest amended loan balances, fees, warrants, shares and available ATM capacity cannot be reconciled from the acquired disclosures.
A passing modeled return does not establish an investor commitment. Public-cohort rows summarize the dated subscriptions; the workbook contains their individual cash flows.
| Provider | Required / modeled return | Required / modeled MOIC | Hurdle NPV | Economics | Commitment |
|---|---|---|---|---|---|
| P1 senior lenderReturn shown is the contractual coupon assumption, not a separately captured lender IRR. Security, conditions and funding are uncommitted. | 6% / 6% | Unavailable / Unavailable | Unavailable | Pass | Uncommitted |
| P1 outside common investorDated provider return includes capital contributions and contractual receipts. A missing IRR is unavailable, not zero; NPV/MOIC tests are retained. | 12% / Unavailable | 1.5× / 1.72× | $0m | Pass | Uncommitted |
| P1 preferred investorDated provider return includes capital contributions and contractual receipts. A missing IRR is unavailable, not zero; NPV/MOIC tests are retained. | 10% / 10.47% | 1× / 1.04× | $0.46m | Pass | Uncommitted |
| P2 senior lenderReturn shown is the contractual coupon assumption, not a separately captured lender IRR. Security, conditions and funding are uncommitted. | 6% / 6% | Unavailable / Unavailable | Unavailable | Pass | Uncommitted |
| P2 outside common investorDated provider return includes capital contributions and contractual receipts. A missing IRR is unavailable, not zero; NPV/MOIC tests are retained. | 12% / Unavailable | 1.5× / 1.75× | $6m | Pass | Uncommitted |
| P2 preferred investorDated provider return includes capital contributions and contractual receipts. A missing IRR is unavailable, not zero; NPV/MOIC tests are retained. | 10% / 10.45% | 1× / 1.04× | $1.08m | Pass | Uncommitted |
| Parent public-issuance cohortsMinimum captured cohort MOIC and sum of cohort NPVs. Assumed issue price and gross ceiling do not establish market access or available ATM capacity. | 11% / Unavailable | 1× / 17.08× | $203.41m | Pass | Uncommitted |
This captured subtotal reflects the allocation to the original shareholders after financing claims, taxes and dilution. The workbook contains the detailed bridge. Present values are distinct from nominal financing proceeds.
Modeled date: 2026-10-08
Dated financing assumption; new shares are included in original-holder dilution and public-cohort return tests.
Modeled date: 2026-11-01
Unspecified hypothetical bank-acceptable additional credit support; no validated NUAI unsecured LC line or credit loss underwriting. Actual bank approval/credit limit not evidenced.
Modeled date: 2026-11-01
Conditional schedule; not a drawable commitment.
Modeled date: 2029-04-01
Conditional schedule; not a drawable commitment.
Modeled date: 2038-04-01
Future common/NUAI capital support is included in lifecycle calls and priced provider returns. No unpriced refinancing proceeds are assumed.
Modeled date: 2041-03-01
Future common/NUAI capital support is included in lifecycle calls and priced provider returns. No unpriced refinancing proceeds are assumed.
Independent debt, equity, offtake and delivery
UnverifiedProvider economics pass conditionally; binding capacity offtake, fuel pass-through, external commitments and delivery remain unverified.
Selecting a case changes the displayed frozen result. It does not rerun the financing engine, update market prices or accept new inputs. Use the editable workbook for recalculation.
Captured results SHA-256: c9ecfb57f8ad9d7a8f4f8128fbf1b8e3e4c5a97432ea6034ddaa461cdaa9c389
The optimized captures vary provider claims and ownership. The workbook also contains matched C/D tax comparisons and separately re-underwritten E financing comparisons.
Outside common capital, maturity calls and public subscriptions remain uncommitted. Modeled provider returns are conditions, not evidence that funding is available. Undrawn commitment fees are not separately priced; the ranking does not establish a risk-adjusted market opportunity.
The legal entities, Vistra allocation, partnership allocations and liability basis remain conditional. Suspended losses do not create an immediate cash refund. Outside-investor tax, buyer basis adjustments and entity-specific state or minimum-tax profiles have bounded coverage.
Project liens require Macquarie takeout or documented consent. LC collateral release requires accepted replacement support. Power financing and delivery are independent gates; tenant-owned GPUs are not NUAI collateral, and a power purchase agreement is not a tenant lease.
No tenant contribution or prepaid rent is assumed in the principal cases. The source maintenance amount is a cash reserve, not a proved deductible expense or depreciable investment. Building expensing, bonus depreciation and energy-credit transfer proceeds are not assigned without the required eligibility evidence.
The workbook provides live formulas for eight selected cases and preserves the earlier model sheets as archives. The review memo and QA register document the broader finite grid, inputs and checks. Changing workbook inputs invalidates frozen search comparisons until those outputs are regenerated.
v2.7.1 correction: The check in 27 Funding!C70 now reads minimum Phase 1 DSCR rather than Phase 2 DSCR. Only that cell's formula and cached value were corrected. Assumptions and captured case values are unchanged, and the original v2.7 workbook is preserved. Correction checks are documented separately; the full corrected workbook and upstream schedules were not recalculated in ArtifactTool, Excel or LibreOffice.
NUAI-TCDC-v2.7.1-2026-10-12.xlsx · 9,138,562 bytes
SHA-256: 70fdac8c4b5a3e763fe6ae1dc3304787d2bb5f4a8ee0258fd31626a7fb61bc1d
NUAI-TCDC-v2.7.1-Review-Memo-2026-10-12.pdf · 176,807 bytes
SHA-256: 31e90510cbe2d07831f1f56e6ac72525ad08b95c800a5b38374063c9f5cd2fe6
NUAI-TCDC-v2.7.1-Simple-Explanation-2026-10-12.pdf · 155,242 bytes
SHA-256: c1de0d4bb06856b5138a9f426d4cd27ed78f1bdce122b883f2f583ab0c6c0659
NUAI-TCDC-v2.7.1-Source-Change-QA-Register-2026-10-12.md · 104,752 bytes
SHA-256: 276113ea3b5373704a8b7bd960e31942cd99f31c4e861a44374fe40be04cde65
NUAI-TCDC-v2.7.1-File-Manifest-2026-10-12.json · 206,199 bytes
SHA-256: a13e105bef8359ee48a0f00cdf4d6398ac471fc150781535ab1fdbc23cea4cb4
The five public v2.7.1 files document the narrow workbook correction and preserve its original-source lineage. The original v2.7 files remain unchanged. Publication does not turn conditional financing into executed commitments. The reproducibility ZIP remains private.
The release records 160,224 active formulas, 310,631 selected schedule and aggregate comparisons, and 8 live workbook selectors. The finite run contains 805 results, 117 conditional economic passes and 0 verified executable project packages. These counts concern original v2.7 preparation, not full corrected-workbook validation. They do not prove a global optimum.
@oai/artifact-tool 2.8.91; portable finance engine 2.7.2026-10-12-taxpayer-contract-1.
No native Excel or LibreOffice calculation was performed. ArtifactTool authored and calculated the active workbook, then recalculated saved components and the final merged workbook. Original archive financial models were preserved, not revised or financially revalidated.
The file manifest and QA register distinguish original v2.7 workbook checks from the focused v2.7.1 correction checks. The recorded October 11 Pacific research date does not certify exhaustive end-of-day coverage. Tax payment dates are planning conventions, not a prepared tax return.
Review the NUAI source library. The downloadable register contains the release-specific legal and tax evidence and its limitations.
This correction updates the minimum Phase 1 DSCR reference and cached value in one workbook cell. It preserves v2.7's assumptions, captured values, tax and ownership calculations, and original artifacts. The underlying v2.7 model added direct-leasing strategy costs, taxpayer-level depreciation and interest restrictions, owner basis and loss capacity, disposal tax, and re-underwritten financing and ownership. Historical v2.6 and v2.1 releases remain available separately.