v3.26.1
Income Taxes
9 Months Ended
Dec. 31, 2025
Income Tax Disclosure [Abstract]  
Income Taxes

Note 10. Income Taxes

 

The Company has elected to be regulated as a BDC under the 1940 Act as of April 15, 2025. The Company intends to elect as a RIC for the year ended December 31, 2025 and intends to qualify each taxable year thereafter. As a RIC, the Company generally is not subject to corporate-level U.S. federal income taxes on any ordinary income or capital gains that it timely distributes as dividends for U.S. federal income tax purposes to its stockholders. To qualify to be treated as a RIC, the Company is required to meet certain source of income and asset diversification requirements, and to timely distribute dividends out of assets legally available for distributions to its stockholders of an amount generally equal to at least 90% of the sum of its net ordinary income and net short-term capital gains in excess of net long-term capital losses, if any, for each taxable year.

Taxable income differs from net increase (decrease) in net assets resulting from operations primarily due to: (1) unrealized appreciation (depreciation) on investments, as gains and losses are generally not included in taxable income until they are realized; (2) income or loss recognition on foreign currency transactions; (3) significant debt modifications; and (4) other non-deductible expenses.

The Company makes certain adjustments to the classification of net assets as a result of permanent book-to-tax differences, which include differences in the book and tax basis of certain assets and liabilities, and non-deductible expenses, among other items. To the extent these differences are permanent, they are charged or credited to paid in capital, accumulated net distributable earnings (losses), as appropriate. For the period from April 15, 2025 (inception) to December 31, 2025, permanent differences were as follows:

 

 

Period from April 15, 2025 (inception) to December 31, 2025

 

Accumulated net distributable earnings (losses)

 

$

26

 

Paid-in capital in excess of par value

 

 

(26

)

 

During the period from April 15, 2025 (inception) to December 31, 2025, permanent differences were related to non-deductible expenses.

 

The following reconciles the increase in net assets resulting from operations to taxable income for the period from April 15, 2025 (inception) to December 31, 2025:

 

 

 

Period from April 15, 2025 (inception) to December 31, 2025

 

Net increase (decrease) in net assets resulting from operations

 

$

3,094

 

Net unrealized (appreciation) depreciation

 

 

(219

)

Realized gain (loss) for tax not included in book income

 

 

(105

)

Capital losses carried forward

 

 

124

 

Other non-deductible expenses and excise taxes

 

 

54

 

Other book/tax differences

 

 

220

 

Total taxable income

 

$

3,168

 


The components of accumulated net distributable earnings (losses) as calculated on a tax basis for the period from April 15, 2025 (inception) to December 31, 2025 were as follows:

 

 

Period from April 15, 2025 (inception) to December 31, 2025

 

Undistributed ordinary income

 

$

464

 

Accumulated capital and other losses

 

 

(124

)

Accumulated net unrealized appreciation (depreciation)

 

 

310

 

Other book/tax differences

 

 

(28

)

Total accumulated net distributable earnings (losses)

 

$

622

 

 

The cost and unrealized gain (loss) of the Company’s investments, as calculated on a tax basis, for the period from April 15, 2025 (inception) to December 31, 2025 is as follows:

 

 

Period from April 15, 2025 (inception) to December 31, 2025

 

Gross tax unrealized appreciation

 

$

453

 

Gross tax unrealized depreciation

 

 

(146

)

Net unrealized appreciation (depreciation)

 

$

307

 

 

 

 

 

Tax cost

 

$

152,938

 

 

The difference between GAAP-basis and tax basis unrealized gains (losses) is attributable primarily due to significant modification of debt securities.

 

Capital losses are generally eligible to be carried forward indefinitely and retain their status as short-term or long-term in the manner originally incurred by the Company. The Company incurred capital losses for the period from April 15, 2025 (inception) to December 31, 2025 as follows:

 

 

Period from April 15, 2025 (inception) to December 31, 2025

 

Short-term capital loss

 

$

(124

)

Long-term capital loss

 

$

 

 

The tax character of distributions paid may differ from the character of distributions shown in the Statement of Changes in Net Assets due to short-term capital gains being treated as ordinary income for tax purposes. The tax character of distributions paid during the tax year ended December 31, 2025 were as follows:

 

 

 

Period from April 15, 2025 (inception) to December 31, 2025

 

Distributions paid from Ordinary Income

 

$

2,498

 

 

For the fiscal year ended December 31, 2025, the Company, designates 100% of dividends allowable pursuant to the Internal Revenue Code 163(j) as interest income eligible for income inclusion for corporate shareholders.

 

ASTII Equity Holdings LLC, a wholly owned subsidiary formed in 2025, is a Delaware LLC which has elected to be treated as a corporation for U.S. tax purposes. As such, ASTII Equity Holdings LLC is subject to U.S. federal, state and local taxes. For the Company's tax year ended December 31, 2025, ASTII Equity Holdings LLC activity did not result in a material provision for income taxes.

 

For the fiscal year ended December 31, 2025, the Company designates investment expenses of $205 under Treasury Regulation Section 1.67-2T(e).

 

Management has analyzed the Company’s tax positions taken, or to be taken, on federal income tax returns for all open tax years and has concluded that no provision for income tax is required in the Company’s financial statements. The Company’s federal and state tax returns are subject to examination by the Internal Revenue Service and state tax authorities for a period of three fiscal years after they are filed.