To everyone questioning SpaceX / $SPCX’s highly successful IPO and its $2.1T market cap, let me share what I believe is the best arbitrage setup.

Do you know $SATS?

$SATS is expected to receive 261.8M shares of $SPCX, worth roughly $42B based on the 6/12 closing price.

Yet SATS’ current market cap is only about $33B.

Short: $SPCX
Long: $SATS

$SATS will effectively own approximately 2% of SpaceX / SPCX.

According to the SPCX prospectus, in exchange for acquiring spectrum from SATS, SPCX will pay SATS 261.8M shares of SPCX stock, roughly $8.5B in cash, and an additional ~$2.0B in cash to cover interest payments that SATS would otherwise have been responsible for.

In addition, SATS is expected to sell roughly $23B of spectrum to $T.

The transactions with $T and SPCX were approved by the FCC on 5/12. If no petition for reconsideration was filed by 6/11, the approval should likely have become final automatically. As of 6/14, I have not confirmed any petition for reconsideration.

Also, the spectrum transfer structure is SATS → TRUST → SPCX. Since the SATS → TRUST transfer has already been completed, I believe the closing risk is relatively low.

Now let’s calculate $SATS NAV.

My base NAV assumptions:

SPCX ownership: approximately 2%

SATS basic shares outstanding: 298M

Fully diluted shares after convertible bonds: 348M

I use 348M shares in the calculation below.

Cash proceeds from spectrum sales to $T and $SPCX:

From $T: approximately $23B
From $SPCX: approximately $8B in cash
Total: approximately $31B

Assuming the convertible bonds are converted into equity, net cash after debt repayment would be roughly $11B.

Regulatory / escrow / contingent liability haircut: -$2.5B

Net cash after haircut: approximately $8.5B

Remaining operating business value: $10B

Based on roughly $300M of operating income in Q1 2026 × 4 quarters × 8x multiple.

Even after the spectrum sales to $T and $SPCX, SATS will retain remaining spectrum assets. The most notable example is AWS-3 paired spectrum, which SATS previously planned to sell to $VZ for approximately $9.8B.

If we conservatively value the remaining spectrum at $10B, that adds approximately $28.7 per share of NAV based on 348M shares.

Formula:

SATS NAV
= {SPCX market cap × 2% + net cash after haircut + remaining operating business value + remaining spectrum value} / 348M shares

= {SPCX market cap × 2% + $8.5B + $10B + $10B} / 348M shares

SATS NAV by SPCX market cap:

• SPCX $2.0T → SATS approximately $197
• SPCX $2.25T → SATS approximately $211
• SPCX $2.5T → SATS approximately $226
• SPCX $2.75T → SATS approximately $240
• SPCX $3.0T → SATS approximately $254

This is my personal analysis, not financial advice.

I think the tax treatment around $SATS’ spectrum sales is widely misunderstood.

A lot of people seem to be doing this:

Total $T / $SPCX transaction value × 21%

That is the wrong framework.

Taxes are not applied to gross proceeds.
They are applied to taxable gain.

Here is the potential consideration:

$T transaction:

• Cash consideration: ~$22.65B

$SPCX transaction:

• SPCX equity: 261.8M shares × $42.40 = ~$11.1B
• SPCX cash: ~$8.5B
• SPCX interest coverage: ~$2.0B

Total potential consideration:

$22.65B + $11.1B + $8.5B + $2.0B
= ~$44.25B

At first glance, that looks like a huge tax base.

But it is not taxable gain.

There are major offsets that need to be considered.

SATS has invested more than $30B in wireless spectrum licenses.

That figure does not include roughly $10B of capitalized interest.

So on a historical investment basis, we are talking about more than $40B of spectrum-related investment.

Not all of that necessarily becomes the tax basis for the specific spectrum being sold to $T and $SPCX.

But the point is simple:

Against ~$44.25B of gross consideration, the potential tax basis may be very large.

There is also the 2025 loss.

SATS recorded:

• Net loss: ~$14.5B
• Non-cash asset impairment and other charges: ~$17.6B

A non-cash accounting impairment does not mean the same amount of cash left the business.

And even if assets are impaired for accounting purposes, tax basis may remain meaningfully higher than accounting carrying value.

So the tax calculation needs to consider:

• Tax basis of the spectrum sold
• Accumulated losses
• NOLs / tax loss carryforwards
• Deferred tax assets
• Other available deductions

The wrong calculation is:

$44.25B × 21%
= ~$9.3B of tax

That is likely overstated.

The better framework is:

Taxable income
= transaction consideration
− tax basis of spectrum sold
− usable NOLs / loss carryforwards
− other tax deductions

Then corporate tax is applied to the remaining amount.

My rough tax range:

• Bull case: $0–0.5B
• Base case: $1.0–2.0B
• Conservative case: $2.5–4.0B

Another important point is the SPCX equity.

The SPCX shares SATS receives are contractually valued at:

261.8M shares × $42.40
= ~$11.1B

So the equity consideration should first be viewed on a $42.40/share basis.

If SPCX trades at $180 after the IPO, the upside above $42.40 should generally remain unrealized unless SATS sells the shares.

In other words, I do not assume immediate taxation on the post-IPO mark-to-market upside of the SPCX shares.

Conclusion:

Looking at $SATS tax as:

$44.25B gross transaction value × 21%
= ~$9.3B tax

is far too simplistic.

The relevant numbers are:

• Gross consideration: ~$44.25B
• Spectrum-related investment: more than $30B
• Capitalized interest: ~$10B
• 2025 net loss: ~$14.5B
• 2025 non-cash impairment and other charges: ~$17.6B
• SPCX equity consideration: $42.40/share basis
• Post-IPO upside in SPCX shares should not be taxed immediately unless SATS sells

My base case is that actual cash taxes could be closer to $1.0–2.0B, not $9.3B.

And even this does not materially change my NAV framework.

Why?

Because my NAV calculation is already conservative.

When valuing the remaining operating business, I do not include the benefit from being released from extremely burdensome interest expenses.

When calculating balance sheet value, I exclude SATS assets other than spectrum and cash.

And for the ~$2.0B of interest coverage to be received from SPCX, the portion SATS has already paid should effectively be treated like a receivable.

I have not included that either.

So the point is not that taxes are zero.

The point is that “gross proceeds × 21%” is not the right starting point.

To all $SBET holders:
I know many of you feel frustration or anxiety over the recent price action. But let me explain why there’s no need to worry.

The true essence of a treasury company is leverage through debt financing. Yet most $ETH treasury company rely solely on equity financing — which naturally keeps their mNAV stuck around 1.