v3.25.4
Tax Information
 12 Months Ended
Dec. 31, 2025
Income Tax Disclosure [Abstract]  
Tax Information

11. TAX INFORMATION

 

The below table presents the tax character of distributions:

 

 

Year Ended
December 31, 2025

 

 

Year Ended
December 31, 2024

 

 

Year Ended
December 31, 2023

 

Distributions paid from:

 

 

 

 

 

 

 

 

 

Ordinary Income

 

$

32,099

 

 

$

5,385

 

 

$

50,579

 

Net Long-Term Capital Gains

 

 

—

 

 

 

—

 

 

 

—

 

Total Taxable Distributions

 

$

32,099

 

 

$

5,385

 

 

$

50,579

 

Tax Return of Capital

 

$

29,015

 

 

$

125,320

 

 

$

—

 

 

As of the dates indicated, the components of Accumulated Earnings (Losses) on a tax basis were as follows:

 

 

 

December 31, 2025

 

 

December 31, 2024

 

 

December 31, 2023

 

Undistributed Ordinary Income—net

 

$

—

 

 

$

—

 

 

$

27

 

Undistributed Long-Term Capital Gains

 

 

—

 

 

 

—

 

 

 

—

 

Total Undistributed Earnings

 

$

—

 

 

$

—

 

 

$

27

 

Capital Loss Carryforward: (1)

 

 

 

 

 

 

 

 

 

Perpetual Short-Term

 

$

(3,074

)

 

$

—

 

 

$

(33

)

Perpetual Long-Term

 

 

(110,251

)

 

 

(58,822

)

 

 

(42,892

)

Timing Differences (Organizational Costs/Incentive Fees/Late Year Ordinary Loss Deferral/Post-October Loss Deferral/ 852(b)(7) Dividend)

 

 

(2,549

)

 

 

(19,492

)

 

 

(78,572

)

Unrealized Earnings (Losses)—net

 

 

(22,529

)

 

 

(77,982

)

 

 

(21,616

)

Total Accumulated Earnings (Losses)—net

 

$

(138,403

)

 

$

(156,296

)

 

$

(143,086

)

 

(1)
For the years ended December 31, 2025, 2024 and 2023, the Company did not utilize any capital losses.

The Company's ability to utilize its capital loss carryforwards is subject to an annual limitation under section 382 of the Code.

 

As of the dates indicated, the Company’s aggregate unrealized appreciation and depreciation based on cost for U.S. federal income tax purposes were as follows:

 

 

December 31, 2025

 

 

December 31, 2024

 

 

December 31, 2023

 

Tax cost

 

$

492,612

 

 

$

661,891

 

 

$

545,083

 

Gross unrealized appreciation

 

 

7,905

 

 

 

3,633

 

 

 

6,412

 

Gross unrealized depreciation

 

 

(30,434

)

 

 

(81,615

)

 

 

(28,028

)

Net unrealized investment appreciation on investments

 

$

(22,529

)

 

$

(77,982

)

 

$

(21,616

)

 

The difference between GAAP-basis and tax basis unrealized gains (losses) is attributable primarily to net mark to market gains/(losses) on foreign currency contracts and differences in the tax treatment for material modification of debt securities.

 

In order to present certain components of the Company’s capital accounts on a tax-basis, certain reclassifications have been recorded to the Company’s accounts. These reclassifications have no impact on the net asset value of the Company and result primarily from certain non-deductible expenses, net operating losses, return of capital distributions, and differences in the tax treatment of underlying fund investments. For the years ended December 31, 2025, 2024 and 2023, the Company reclassified $(2,319) $(34,254), and $(294), respectively, from total distributable earnings to Units.

 

The following table reconciles net increase in net assets resulting from operations to taxable income:

 

 

December 31, 2025

 

 

December 31, 2024

 

 

December 31, 2023

 

Net increase (decrease) in members' capital resulting from operations

 

$

30,807

 

 

$

(13,539

)

 

$

52,302

 

Adjustments:

 

 

 

 

 

 

 

 

 

Net unrealized loss (gain) on investments and foreign currency forward contracts and translations

 

$

(60,914

)

 

$

49,258

 

 

$

(57,505

)

Income not currently taxable

 

 

19,186

 

 

 

(365

)

 

 

295

 

Income for tax but not for book

 

—

 

 

 

178

 

 

 

223

 

Expenses not currently deductible

 

—

 

 

—

 

 

 

9,231

 

Expenses for tax but not for book

 

 

(1,631

)

 

 

(52,916

)

 

 

(325

)

Realized gain (loss) differences

 

 

(63,316

)

 

 

(47,517

)

 

 

3,460

 

Taxable income net of capital loss carryforward

 

$

(75,868

)

 

$

(64,901

)

 

$

7,681

 

Capital loss carryforward

 

$

113,325

 

 

$

58,823

 

 

$

42,925

 

Nondeductible net investment loss

 

$

—

 

 

$

6,078

 

 

$

—

 

Taxable income(1)

 

$

37,457

 

 

$

-

 

 

$

50,606

 

 

(1) Taxable income is an estimate and is not fully determined until the Company’s tax return is filed.

ASC Topic 740 Accounting for Uncertainty in Income Taxes (“ASC 740”) provides guidance on the accounting for and disclosure of uncertainty in tax position. ASC 740 requires the evaluation of tax positions taken or expected to be taken in the course of preparing the Company’s tax returns to determine whether the tax positions are “more-likely-than-not” of being sustained by the applicable tax authority. Tax positions deemed to meet the more-likely-than-not threshold are recorded as a tax benefit or expense in the current year. Based on its analysis of its tax position for all open tax years (the current and prior years, as applicable), the Company has concluded that it does not have any uncertain tax positions that met the recognition or measurement criteria of ASC 740. Such open tax years remain subject to examination and adjustment by tax authorities.