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Wyoming's $102 Test

At Mining Disrupt Miami 2022, Wyoming attorney Bob Cornish laid out the state's digital asset laws and his case for keeping U.S. raises inside its borders.

Oct 15, 20263 min read · 411 wordsRecorded Jul 26, 2022Bob Cornish

One hundred and two dollars. That is the number Bob Cornish asked a room of Bitcoin miners to remember at Mining Disrupt Miami 2022. Cornish is the managing shareholder of the Law Offices of Robert V. Cornish, Jr., a Wyoming attorney who says he helped write some of the state's banking, securities and lending laws for the blockchain industry.

The talk was recorded July 26 to 28, 2022, when Bitcoin traded at $22,964. As of October 12, 2026, it was $84,128.

That summer, the SEC and Coinbase were in the news, and some operators were having second thoughts about keeping their business in the United States. Cornish's answer was Wyoming. In his words, "you can still rock in America, you just have to do it in Wyoming."

He described the state as a marketplace of its own. Inside its borders, anyone can trade with anyone else in the state: 500,000 people and hundreds of thousands of corporations, 40,000 of them with blockchain or crypto in their names. A company in Florida, Canada or Uzbekistan can form a Wyoming LLC as easily as a local.

He listed what comes with it. Digital assets are personal property, with no state tax on their disposition. Lenders can take a security interest in crypto and repossess it. Wyoming had just created chancery courts like Delaware's. Banks generally cannot turn clients away for being in crypto. Trust companies can custody a miner's wallet. Series LLCs let one master company hold a separate cell for each mining rig. And miners can negotiate power one on one with local utilities, without going to a public utility commission.

Then came money. For investors abroad, he pointed to Regulation S offerings made entirely outside the United States. For American investors, he proposed keeping the offering inside Wyoming: investors form their own Wyoming LLC, partnership or trust and are treated as residents.

That is where the 102 comes in. It is what Cornish said it costs to form a one-person LLC in Wyoming. His test for funders and partners was blunt: "my view is they can't spend 102 on you, why should you be dealing with them."

He did not call it a free pass. Investors still have to state that they are Wyoming residents, marketing restrictions still apply, and he said nobody is ever exempt from tax.

The full story is on Mining Disrupt at miningdisrupt dot com, and many more like it play around the clock on Bitcoin Radio.

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