v3.26.1
Income Taxes
11 Months Ended
Dec. 31, 2025
Income Tax Disclosure [Abstract]  
Income Taxes
8.
Income Taxes

The Company has elected to be regulated as a BDC under the 1940 Act and also intends to elect to be treated as a RIC under the Code and will make such an election beginning with the taxable year ending December 31, 2025. So long as the Company maintains its status as a RIC, it will generally not pay corporate-level U.S. Federal income or excise taxes on any ordinary income or capital gains that it distributes at least annually to its Shareholders as dividends. The Company evaluates tax positions taken or expected to be taken in the course of preparing its consolidated financial statements to determine whether the tax positions are “more-likely-than-not” to be sustained by the applicable tax authority. Tax positions not deemed to meet the “more-likely-than-not” threshold are reversed and recorded as a tax benefit or expense in the current year. All penalties and interest associated with income taxes are included in income tax expense. Conclusions regarding tax positions are subject to review and may be adjusted at a later date based on factors including, but not limited to, on-going analyses of tax laws, regulations and interpretations thereof.

8.
Income Taxes (continued)

Federal Income Taxes: It is the policy of the Company to comply with the requirements of the Internal Revenue Code applicable to regulated investment companies and distribute all of its net taxable income and any net realized gains on investments to its shareholders. Therefore, no federal income tax provision is required.

 

As of December 31, 2025, the Company’s aggregate investment unrealized appreciation and depreciation for federal income tax purposes were as follows:

 

 

2025

 

Cost of investments for federal income tax purposes

 

$

721,786

 

Unrealized appreciation

 

$

2,831

 

Unrealized depreciation

 

$

(487

)

Net unrealized (depreciation) appreciation on investments

 

$

2,344

 

The following reclassifications have been made for the permanent difference between book and tax accounting as of December 31, 2025. These differences result from differences in accounting for partnership interests prior to Conversion:

 

 

 

2025

 

Common Unitholders tax reclassification

 

$

314

 

Undistributed net investment (loss) income

 

$

(300

)

Accumulated net realized gain (loss)

 

$

(14

)

 

The tax character of shareholder distributions attributable to the period ended December 31, 2025 was as follows:

 

 

 

2025

 

Ordinary income

 

$

1,671

 

Long-term capital gain

 

$

 

Return of capital

 

$

314

 

The tax components of distributable earnings on a tax basis for the period ended December 31, 2025:

 

 

 

2025

 

Net tax appreciation (depreciation)

 

$

1,780

 

Other cumulative effect of timing differences

 

$

(3,022

)

As of December 31, 2025, the Company had a net long-term capital loss carryforward of $0 for federal income tax purposes, which may be carried forward indefinitely. These capital loss carryforwards are available to offset net realized gains in future years, thereby reducing future taxable gains distributions.

The Company did not have any unrecognized tax benefits as of December 31, 2025, nor were there any increases or decreases in unrecognized tax benefits for the period then ended; therefore, no interest or penalties were accrued. The Company files U.S. federal, state, local and non-U.S. tax returns, as applicable. The Company is subject to examination by U.S. federal and state tax authorities regarding returns filed”