Illustrative sizing · $5mm net to Project

Unit Economics & Scenarios

Every figure below traces to the same arithmetic: $100 lent becomes 79.5 of Treasury collateral, 8.57 of prefunded tax and fees, and 11.93 of growth capital on top of an existing 100 of enterprise value.

Per-$100 walkthrough

  1. Step 1

    Lender lends $100

    79.5 UST STRIPS (→ 100 at yr 5) · 8.57 tax prefund + fees · 11.93 capital to the Project, advanced in two equal tranches (5.97 at closing, 5.97 into milestone escrow released against agreed KPIs at a test date set at closing)
  2. Step 2

    Project capital

    existing 100 + new 11.93 = working base 111.93
  3. Step 3

    Warrant — 20% of the fully diluted capitalisation

    20% of 111.93 = 22.39 · denominator 100 + 22.39 = 122.39 · 22.39 / 122.39 = 18.29% of the enterprise
  4. Step 4

    Unit allocation for tax (§1273(c)(2)), by appraisal

    warrant 4.77 · founding participation 3.22 · note issue price 92.01 · OID 7.99, accreting back to 100

Step 3 is the warrant's share of the enterprise; step 4 is how the purchase price is allocated for tax. They are different measures.

Three scenarios per $100

Enterprise value compounds off the 111.93 working base for five years.

Project CAGR

50%

111.93 capital → 7.6× → 853.0

Enterprise value yr 5
853.0
Note principal outstanding
100.0
LTV
11.72%
Lender equity — 20% × (EV − 100)
150.6
+ Principal repaid at maturity
100.0
Total per $100250.6
MOIC2.51x
IRR20.17%

Principal claimable any time · par at maturity.

Project CAGR

100%

111.93 capital → 32.0× → 3,594.9

Enterprise value yr 5
3,594.9
Note principal outstanding
100.0
LTV
2.78%
Lender equity — 20% × (EV − 100)
699.0
+ Principal repaid at maturity
100.0
Total per $100799.0
MOIC7.99x
IRR51.53%

Principal claimable any time · par at maturity.

Project CAGR

150%

111.93 capital → 97.7× → 10,971.9

Enterprise value yr 5
10,971.9
Note principal outstanding
100.0
LTV
0.91%
Lender equity — 20% × (EV − 100)
2,174.4
+ Principal repaid at maturity
100.0
Total per $1002,274.4
MOIC22.74x
IRR86.80%

Principal claimable any time · par at maturity.

Illustrative example only; all figures are hypothetical. Not an offer, a solicitation, or tax, legal, insurance, or investment advice. Cash-neutrality assumes a 21% federal corporate rate; state tax, other rates, and AMT/BEAT/CAMT change the required coupon.

Returns shown describe the investment unit itself and are before any advisory fee charged by an investor's own adviser, which is paid by the investor outside the structure.

Interactive calculator

Move the CAGR to see the Lender's total per $100. Below refinance capacity the panel switches to the floor state — MOIC never prints below 1.00x.

%
−20%+160%
Capital base
111.93
Note
100
Warrant
20%

Total to Lender per $100 lent across the CAGR range; the marker is the current setting.

Results per $100 lent

Enterprise value yr 5

3,581.8

LTV

2.792%

Lender equity (20%)

696.4

Total to Lender

796.4

MOIC

7.96x

IRR

51.43%

Returns shown describe the investment unit itself and are before any advisory fee charged by an investor's own adviser, which is paid by the investor outside the structure.

Per $100 lent. Illustrative only — see the sizing-specific scenario table for modeled outcomes.

Scenario table — $5mm net to Project

Modeled outcomes at the selected sizing. FAIL is the floor case, labelled FAIL.

Modeled scenario outcomes at $5mm net to Project sizing, from FAIL through HIGH.
MeasureFAILLOWBASEHIGH
Project CAGR-9.7%50%100%150%
Enterprise value yr 5$30.02mm$379.69mm$1.60bn$4.88bn
Refinance of the bulletNot availableRefinanced or repaid in fullRefinanced or repaid in fullRefinanced or repaid in full
Equity value yr 5 (Project's 40% cell option applied)$0$354.53mm$1.57bn$4.86bn
Lender proceeds$42.81mm$117.49mm$361.63mm$1.02bn
Principal sourceTreasury claim (auto-filed)Project repaymentProject repaymentProject repayment
20% warrant$0$70.91mm$314.97mm$971.53mm
9% cell participation (in STRIPS; at delivery value where the put trips)Forfeited$3.77mm$3.62mm$3.45mm
Unearned premium returned on early distribution$228,648$461,131
MOIC1.00x after-tax (1.02x gross)2.80x8.63x24.29x
IRR0.425%22.996%55.969%93.612%
LTV139.65%11.04%2.62%0.86%
Success put triggered (EV ≥ 20x note face)Not reachedNot reachedYr 4.1Yr 3.1
Cell interests (Project / founding investors)ForfeitedVestVestVest
Modeled scenario outcomes at $5mm net to Project sizing, from FAIL through HIGH.

Illustrative example only; all figures are hypothetical. Not an offer, a solicitation, or tax, legal, insurance, or investment advice. Cash-neutrality assumes a 21% federal corporate rate; state tax, other rates, and AMT/BEAT/CAMT change the required coupon.

Where the success put trips, the Lender receives at the put date its principal, the unused coupon reserve, its cell participation in STRIPS and the unearned premium on the distributed STRIPS, while the Warrant runs to maturity.

Returns shown describe the investment unit itself and are before any advisory fee charged by an investor's own adviser, which is paid by the investor outside the structure.

Lender interest schedule

Constant-yield accrual at 2.1264% with a stated coupon of 0.425% ($178,101/yr).

Lender interest schedule at $5mm net to Project sizing: adjusted issue price, stated interest, OID accrual, tax at 21%, and net cash.
YrAdjusted issue priceQSI cashOID accrualTotal interestTax @ 21%Net cash
1$38,573,414$178,101$642,106$820,207$172,243$5,858
2$39,215,520$178,101$655,760$833,861$175,111$2,990
3$39,871,280$178,101$669,703$847,804$178,039$62
4$40,540,983$178,101$683,944$862,045$181,029-$2,928
5$41,224,927$178,101$698,487$876,588$184,083-$5,982
Total$41,923,414$890,505$3,350,000$4,240,505$890,505$0
Lender interest schedule at $5mm net to Project sizing: adjusted issue price, stated interest, OID accrual, tax at 21%, and net cash.

Illustrative example only; all figures are hypothetical. Not an offer, a solicitation, or tax, legal, insurance, or investment advice. Cash-neutrality assumes a 21% federal corporate rate; state tax, other rates, and AMT/BEAT/CAMT change the required coupon.

Note issue price $38,573,414 = face $41,923,414 less the appraised allocation to the Warrant ($2,000,000) and the founding participation ($1,350,000). The difference, $3,350,000, is the original issue discount that accretes to face over five years in the schedule above. It exceeds the de minimis threshold of $524,043 (0.25% of face for each of the five years), so it is reported as OID.

Why this closes exactly

Each year's adjusted issue price plus that year's OID equals the next year's — the chain terminates exactly at face. The tax column sums exactly to the coupon reserve, and net cash to the Lender sums to zero. That is what “cash-neutral” means.

How it quotes

The paper is quoted against a maturity-matched Treasury comparison.

Option 1

UST 4.125% 7/31/31

Size · bid–ask
$50mm x $50mm · 98.773 x 98.781
Mark yield
4.401% x 4.401%
Mid
98.764 (4.4025%)

Option 2

PROJECT 0.425% 7/31/31

Size · bid–ask
$50mm x $50mm · 79.50 x 862.59Bid 79.50 = Treasury floor at closing (STRIPS cost per $100 of face). Ask = BASE-case value per $100 at year 5.
Mark yield
4.695% x −55.969%Bid yield = STRIPS accretion to par; ask yield = BASE-case IRR, sign reversed.
Mid
100.000 (0.425% current)
FAIL-case price
102.12 gross (≈100.00 after tax)

Illustrative example only; all figures are hypothetical. Not an offer, a solicitation, or tax, legal, insurance, or investment advice. Cash-neutrality assumes a 21% federal corporate rate; state tax, other rates, and AMT/BEAT/CAMT change the required coupon.