Exhibit 8.1

Loeb & Loeb LLP   10100 Santa Monica Blvd.
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September 30, 2022

Brilliant Acquisition Corporation
99 Dan Ba Road, C-9, Putuo District,
Shanghai, Peoples Republic of China
Attn: Dr. Peng Jiang

Re: Registration Statement of Nukkleus Inc.

Ladies and Gentlemen:

We have acted as United States counsel to Brilliant Acquisition Corporation, a British Virgin Islands company, (“Brilliant”), in connection with the proposed Business Combination (as defined below) contemplated by an Agreement and Plan of Merger, dated as of February 22, 2022 (as may be amended from time to time, the “Merger Agreement”), by and among Brilliant, Nukkleus Inc., a Delaware corporation (“Nukkleus”), and NB Merger Sub, Inc., a British Virgin Islands company and wholly-owned subsidiary of Nukkleus (“Merger Sub”), pursuant to which the Merger Sub will merge with and into Brilliant, with Brilliant surviving the Business Combination as a wholly-owned subsidiary of Nukkleus (the “Merger”)(collectively with the other transactions described in the Merger Agreement, the “Business Combination”).

The Business Combination and certain other related transactions are described in the Registration Statement of Nukkleus Inc. on Form S-4 under the Securities Act of 1933, as amended (the “Securities Act”), filed on August 9, 2022 (Registration Number 333-264334) as amended through the date hereof (the “Registration Statement”).

In rendering this opinion, we have reviewed the Registration Statement and have assumed with your approval the authenticity of all documents submitted to us as originals, the conformity to original documents of all documents submitted to us as copies, and the completeness and accuracy of the documents reviewed by us. We have assumed with your approval and have not verified the accuracy of the factual matters and representations set forth in the Registration Statement.

Based on the foregoing and subject to the assumptions, limitations and qualifications stated in the Registration Statement and herein, we hereby confirm and adopt as our opinion the statements of United States federal income tax law on the date hereof as set forth in the Registration Statement under the caption “Material U.S. Federal Income Tax Consequences — U.S. Holders — U.S. Federal Income Tax Considerations for the Merger.”

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For the United States offices, a limited liability partnership including professional corporations. For Hong Kong office, a limited liability partnership.

Brilliant Acquisition Corporation September 30, 2022 Page 2

This opinion is based upon the existing provisions of the Internal Revenue Code of 1986, as amended, Treasury Regulations promulgated thereunder, published revenue rulings and procedures from the United States Internal Revenue Service (“IRS”) and judicial decisions, all as in effect on the date hereof. Any such authority is subject to change, and any change may be retroactive in effect and may affect our opinion as set forth herein. Our opinion is based on the facts, assumptions and representations set forth in the Registration Statement and this opinion. If any of the facts, assumptions or representations is not true, correct or complete, our opinion may not be applicable. We undertake no responsibility to update this opinion or to advise you of any developments or changes as a result of a change in legal authority, fact, representation, assumption or document, or any inaccuracy in any fact, representation or assumption, upon which this opinion is based, or otherwise.

Our opinion is not binding on the IRS or a court. The IRS may disagree with one or more of our conclusions, and a court may sustain the IRS’s position.

We hereby consent to the filing of this letter as an exhibit to the Registration Statement and to the reference to this firm as counsel to Brilliant under the caption “Material U.S. Federal Income Tax Consequences — U.S. Holders — U.S. Federal Income Tax Considerations for the Merger” in the Registration Statement, without implying or admitting that we are “experts” within the meaning of the Securities Act or the rules and regulations promulgated thereunder, with respect to any part of the Registration Statement, including this exhibit.

Regards,

/s/ Loeb & Loeb LLP

Loeb & Loeb LLP