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

10. TAX INFORMATION

The below table presents the tax character of distributions:

 

 

 

For the Year Ended
December 31, 2025

 

 

For the Year Ended
December 31, 2024

 

 

For the Year Ended
December 31, 2023

 

Distributions paid from:

 

 

 

 

 

 

 

 

 

Ordinary Income

 

$

143,212

 

 

$

147,398

 

 

$

177,199

 

Net Long-Term Capital Gains

 

 

—

 

 

$

7,309

 

 

—

 

Total Taxable Distributions

 

$

143,212

 

 

$

154,707

 

 

$

177,199

 

Tax Return of Capital

 

$

83,736

 

 

$

—

 

 

$

—

 

 

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

 

$

—

 

 

$

60

 

 

$

209

 

Undistributed Long-Term Capital Gains

 

$

—

 

 

$

—

 

 

$

7,260

 

Total Undistributed Earnings

 

$

—

 

 

$

60

 

 

$

7,469

 

Capital Loss Carryforward(1)

 

 

 

 

 

 

 

 

 

    Perpetual Long-Term

 

$

(89,762

)

 

$

(103,341

)

 

$

—

 

    Perpetual Short-Term

 

 

(13,519

)

 

 

(10,107

)

 

—

 

Timing Differences (Late Year Ordinary Loss Deferral/Post - October Loss Deferral/Organizational Costs/Unvested Incentive Fee/§852 (b)(7) Dividend/Distributions Payable)

 

$

(103,137

)

 

$

(33,267

)

 

$

(30,936

)

 Unrealized Earnings (Losses)—net

 

$

(106,010

)

 

$

(68,768

)

 

$

(115,553

)

 Total Accumulated Earnings (Losses)—net

 

$

(312,428

)

 

$

(215,423

)

 

$

(139,020

)

 

(1)
For the years ended December 31, 2025 and December 31, 2024, the Company did not utilize any capital losses. For the year ended December 31, 2023, the Company utilized $3,157 of capital losses.

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

 

$

1,764,757

 

 

$

2,240,301

 

 

$

2,846,750

 

Gross unrealized appreciation

 

 

12,066

 

 

 

17,145

 

 

 

12,027

 

 Gross unrealized depreciation

 

 

(118,076

)

 

 

(85,913

)

 

 

(127,580

)

 Net unrealized investment appreciation on investments

 

$

(106,010

)

 

$

(68,768

)

 

$

(115,553

)

The difference between GAAP-basis and tax basis unrealized gains (losses) is attributable primarily to differences in the tax treatment of underlying fund investments, partnership investments and 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 and differences in the tax treatment of underlying fund investments. For the years ended December 31, 2025, 2024 and 2023, the Company reclassified $59,368, $(8,546) and $1,868 from total distributable earnings to Units.

 

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

 

 

 

For the Year Ended
December 31, 2025

 

 

For the Year Ended
December 31, 2024

 

 

For the Year Ended
December 31, 2023

 

 Net increase in members' capital resulting from operations

 

$

79,311

 

 

$

69,758

 

 

$

105,209

 

 Adjustments:

 

 

 

 

—

 

 

—

 

 Net unrealized loss (gain)

 

 

25,181

 

 

 

(43,100

)

 

 

27,064

 

 Income not currently taxable

 

 

399

 

 

 

(5,582

)

 

 

(2,988

)

 Income for tax but not for book

 

—

 

 

—

 

 

—

 

 Expenses not currently deductible

 

 

13,640

 

 

 

14,128

 

 

 

19,658

 

 Expenses for tax but not for book

 

 

(9

)

 

 

(9

)

 

 

(9

)

 Realized gain (loss) differences

 

 

(103,719

)

 

 

(1,383

)

 

 

35,592

 

Taxable income net of capital loss carryforward

 

$

14,803

 

 

$

33,812

 

 

$

184,526

 

Capital loss carryforward

 

 

103,280

 

 

 

113,449

 

 

—

 

Taxable income(1)

 

$

118,083

 

 

$

147,261

 

 

$

184,526

 

 

(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.