GPU lease to own, for a business buying GPU servers, means a $1-buyout lease: it finances the full cost, and the lessee can buy the systems for $1 when the term ends [3, 22]. Consumer rent-to-own is a different market: IRS Publication 946 describes qualified rent-to-own property as tangible personal property generally used in the home for personal use [11]. The business question is whether a $1-buyout lease, a fair-market-value (FMV) lease or a loan-financed purchase costs less after tax.
The answer turns on inputs a buyer can write down: the price, the lease payment, the loan rate, the tax position and the value of the servers when the term ends. In the worked example below, built on public inputs, the resale estimate moves the answer more than the loan rate or the tax position. Every worked number is our arithmetic and illustrates the method.
Compare after-tax cash flows: the net advantage to leasing
The Association for Financial Professionals treats lease against buy as a discounted cash flow analysis: the after-tax cash flows of leasing against those of owning, discounted at the company's after-tax cost of debt, because debt financing is the alternative to leasing [1]. The difference is the net advantage to leasing (NAL), and a positive NAL means the lease costs less [1].
The servers do the same work either way, so only the financing and tax flows count [1]. For a purchase financed with a loan, the loan's own payments drop out: discounted at the after-tax loan rate, they are worth the amount borrowed (our arithmetic). That leaves three lines for buying: the price, the tax saved by depreciation and the after-tax resale value. Leasing has two: the payments and the tax saved by deducting them.
GPU lease to own against an FMV lease
Who owns the servers for tax decides who claims depreciation. IRS Publication 946 lets a party depreciate leased property only if it keeps the incidents of ownership, among them legal title and the risk of loss through obsolescence, so a lessee generally cannot [11]. In a true tax lease, ELFA writes, the lessor generally keeps the residual value risk and the tax benefits, usually depreciation, and the lessee deducts its payments [4]. Equipment under a $1 purchase option is treated the same as owned equipment by the lessee [4].
The IRS's advance-ruling guidelines for leveraged leases expect the property to be worth at least 20% of its cost at the end of the term, and give no member of the lessee group a right to buy below fair market value [21]. A $1 purchase option, a price below fair market value, is such a right [3, 21]. The two lease forms, and the commercial-law test that separates a lease from a security interest, are set out in GPU financing structures explained.
2026 tax rules: bonus depreciation and Section 179
P.L. 119-21 made full expensing of certain business property permanent [13, 14]. Unless the taxpayer elects out, it must take the 100% allowance for certain qualified property, new or certain used, acquired and placed in service after 19 January 2025 [11]. In a true lease the lessor takes it, and the lessee sees it only as far as it lowers the rent [4, 11]. ELFA writes that lessors pass the benefit on as lower rents compared to a loan, without giving a figure [4].
Section 179 is small against a cluster. For tax years beginning in 2026, its limit is $2,560,000, reduced dollar for dollar once purchases exceed $4,090,000 [12]. At $447,238 for one 8-GPU HGX B200 server, listed on 8 November 2026 [33], ten servers leave a limit of $2,177,620 and 15 leave none (our arithmetic).
Other rules shape a purchase. Section 163(j) limits business interest deductions to business interest income plus 30% of adjusted taxable income and floor plan interest, carrying the excess forward [17]. A loss from a large deduction carries forward and offsets no more than 80% of later taxable income [18]. After a 100% deduction the tax basis is zero, so the resale price is taxed as ordinary income [20].
Lease accounting under ASC 842
Under ASC 842, a lessee records a right-of-use asset and a lease liability for finance and operating leases alike [8]. A lease is a finance lease if it transfers ownership, carries a purchase option the lessee is reasonably certain to exercise, runs for the major part of the asset's economic life, has payments worth substantially all of its fair value, or covers an asset with no alternative use to the lessor [8]. The standard gives 75% of economic life and 90% of fair value as one reasonable approach to two of those tests [8], and PwC notes that it requires no bright lines [9].
A $1 buyout the lessee is reasonably certain to exercise makes a finance lease [8]. PwC writes that an option priced at or above the asset's fair value at commencement generally gives no significant economic incentive based on price [9]. An FMV option is priced at fair value when exercised, so an FMV lease of standard servers turns on the term and payment tests. In the worked example, a three-year lease priced at 10% has payments worth 92.5% of the server's value when the lessor expects a 10% end value and 85.0% when it expects 20% (our arithmetic) [23, 33]. The first is a finance lease under the 90% approach, the second an operating lease if no other test is met [8].
The discount rate is the rate implicit in the lease or, failing that, the lessee's incremental borrowing rate [8]. CoreWeave reported a 10% weighted-average finance lease discount rate for 2025, and Amazon 3.4% [23, 24]. Filed GPU loan rates also move with credit. IREN reported 6.0% on an investment-grade financing and 9.0% fixed on part of its financings supporting non-investment-grade customer deployments [30], the pattern traced across operators in neocloud economics, contract first.
A worked example on one HGX B200 server
The inputs are hypothetical and anchored to cited figures: one $447,238 server [33], a three-year FMV lease paid yearly in advance and priced at 10% [23], a lessor that expects the server to be worth 10% or 20% of its price at the end, 20% being the floor in the IRS guidelines [21], a 9.0% fixed loan [30], 21% federal tax [19] and 100% bonus depreciation [11].
| Present value of cost | Server resells for 0% | 10% | 20% | 30% |
|---|---|---|---|---|
| Buy with a 9.0% loan | $359,552 | $330,800 | $302,047 | $273,295 |
| Lease, lessor expects 20% ($138,925 a year) | $313,313 | $313,313 | $313,313 | $313,313 |
| Lease, lessor expects 10% ($151,208 a year) | $341,015 | $341,015 | $341,015 | $341,015 |
Sources: [11, 19, 21, 23, 30, 33]. The arithmetic is ours, discounted at the after-tax loan rate of 7.11%.
With a lessor expecting 20%, buying costs less only if the server resells for more than 16.1% of its price, and with a lessor expecting 10%, that line falls to 6.4% (our arithmetic). At a 6.78% loan rate, taken from an investment-grade GPU loan that priced "inside the target pricing range of a 6.78% fixed interest rate" [31], the two lines fall to 13.6% and 4.3% (our arithmetic).
Residual value moves the answer
Moving one input at a time from the base case, a 9.0% loan [30] with both sides expecting 20% [21], shows which input matters.
| Input moved | Range | Change in NAL |
|---|---|---|
| Buyer's resale estimate | 0% to 30% of price | $86,258 |
| Lessor's end value | 10% to 20% of price | $27,703 |
| Loan rate | 6.78% to 9.0% | $8,091 |
| Tax use | No tax paid or saved, to 21% used when taken | $6,123 |
Sources: [11, 19, 21, 23, 30, 31, 33]. The arithmetic is ours.
The end value is hard to pin down. CoreWeave, Amazon, Meta and Alphabet book servers over five to six years [23, 24, 25, 26], while NVIDIA's annual report, filed 25 February 2026, describes new data center architectures on a one-year cadence and reduced demand for current generations when customers anticipate transitions [28]. KBRA frames the credit question as whether customers would continue using the capacity at an attractive price after the original term [32]. ELFA's rule of thumb points to an FMV lease for use of 36 months or less, or for equipment expected to become outdated sooner, and in a true lease the lessor carries the obsolescence [3, 4].
Rillor structures and arranges equipment leases and loans for GPU systems with lending and leasing partners, and matches the structure to the deployment and to what lenders need to see.
Renting as a third option
Renting skips both the lease and the purchase. The example lease payment comes to $1.98 per GPU-hour of the year before power, space and staff (our arithmetic) [33], against Lambda's 8-GPU HGX B200 instance price of $7.69 per GPU-hour, listed to take effect on 16 November 2026 [34]. That comparison needs the full ownership cost, which Rent or buy GPUs: a break-even method from public inputs builds from dated public inputs.
Read the full report
The full report adds the formulas and timing conventions, the 2026 tax and ASC 842 rules in detail, the worked example at two loan rates with break-even resale values, book lives from five filers and the complete source list.