Contract analysis

I. Introduction and Engagement Description Calderwood & Harkness LLP has acted as counsel to Calloway-Briggs Renewables Inc., a corporation organized under the laws of the State of Delaware (the "Company" or "CBR"), in connection with the Company's Registration Statement on Form S-1 (File No. [_]; SEC CIK 0001948372) (as amended or supplemented from time to time, the "Registration Statement") filed with the Securitie

II. Scope, Assumptions, and Limitations A. Scope of Opinion This opinion is limited to the material U.S. federal income tax consequences of the purchase, ownership, and disposition of Common Stock by holders who acquire shares in the Offering. Except as expressly noted herein, this opinion does not address: (i) any state, local, or non-U.S. tax consequences that may be relevant to a holder of Common Stock; (ii) any t

III. Definitions For purposes of this opinion, the following definitions shall apply: A. U.S. Holder A "U.S. Holder" is a beneficial owner of Common Stock who is, for U.S. federal income tax purposes, any of the following: (i) an individual who is a citizen or resident of the United States; (ii) a corporation (or other entity treated as a corporation for U.S. federal income tax purposes) created or organized in or un

IV. Tax Consequences to U.S. Holders The following is a discussion of the material U.S. federal income tax consequences of the purchase, ownership, and disposition of Common Stock that are applicable to U.S. Holders. A. Distributions on Common Stock General Rule. Distributions of cash or other property paid on Common Stock will constitute dividends for U.S. federal income tax purposes to the extent paid out of the Co

V. Tax Consequences to Non-U.S. Holders The following is a discussion of the material U.S. federal income tax consequences of the purchase, ownership, and disposition of Common Stock that are applicable to Non-U.S. Holders. A. Distributions on Common Stock General Rule. Subject to the discussion below regarding effectively connected income, distributions treated as dividends (i.e., distributions paid out of current o

VI. Opinion Based upon and subject to the foregoing, and subject to the qualifications, assumptions, and limitations stated herein and in the discussion set forth above, it is the opinion of Calderwood & Harkness LLP that the statements set forth in the Prospectus forming part of the Registration Statement under the caption "Material U.S. Federal Income Tax Consequences," insofar as such statements constitute summari

VII. Limitations and Qualifications This opinion is subject to the following additional limitations and qualifications: (a) This opinion is limited to the matters expressly stated herein, and no opinion is implied or may be inferred beyond such matters. Without limiting the generality of the foregoing, we do not express any opinion regarding any tax consequences relating to assets held by the Company or to the Compan

VIII. Consent to Filing Calderwood & Harkness LLP hereby consents to the filing of this opinion as Exhibit 8.1 to the Registration Statement on Form S-1 of Calloway-Briggs Renewables Inc. (File No. [_]; SEC CIK 0001948372) and to the reference to Calderwood & Harkness LLP under the captions "Material U.S. Federal Income Tax Consequences" and "Legal Matters" in the Prospectus forming part of the Registration Statement

IX. Closing Very truly yours, CALDERWOOD & HARKNESS LLP CALDERWOOD & HARKNESS LLP By: ________ Name: Leonard Cross Title: Specialist Partner, Tax Date: ________ DRAFT — NOT FOR EXECUTION This draft is subject to revision and should not be relied upon as a final opinion. All rights reserved. Calderwood & Harkness LLP.