Tax Matters |
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Jun. 30, 2026 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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| Tax Matters | Note 10. Tax Matters The Company met the criteria to qualify and intends to elect to be treated as a RIC for the period ended December 31, 2025, and intends to continue to qualify annually as a RIC for U.S. federal income tax purposes. So long as the Company qualifies and maintains its tax treatment as a RIC, it generally will not be subject to corporate-level U.S. federal income taxes on any ordinary income or capital gains distributed to Members as dividends. As such, no income taxes were accrued for the six months ended June 30, 2026. Upon the Company’s qualification as a RIC, depending on the level of taxable income earned in a tax year, the Company can be expected to carry forward taxable income (including net capital gains, if any) in excess of current year dividend distributions from the current tax year into the next tax year and pay a nondeductible 4% U.S. federal excise tax on such taxable income, as required. To the extent that the Company determines that its estimated current year annual taxable income will be in excess of estimated current year dividend distributions from such income, the Company will accrue excise tax on estimated excess taxable income. Taxable income for the periods presented appears as follows:
The Company’s taxable income for each period is an estimate and will not be finally determined until the Company files its tax return for each year. Therefore, the final taxable income, and the taxable income earned in each period and carried forward for distribution in the following period, may be different than this estimate. Further, the character of income and gains that the Company distributes is determined in accordance with U.S. income tax regulations that may differ from U.S. GAAP. Book and tax basis differences relating to Member distributions and other permanent book and tax differences are reclassified to paid-in capital. From time to time, the Company may modify its estimates or assumptions regarding its deferred tax liability and/or asset balances and any applicable valuation allowance as new information becomes available. Modifications to the Company’s estimates or assumptions regarding its deferred tax liability and/or asset balances and any applicable valuation allowance, changes in U.S. GAAP or related guidance or interpretations thereof, limitations imposed on or expirations of the Company’s net operating losses and capital loss carryovers (if any) and changes in applicable tax law could result in increases or decreases in the Company’s NAV per Share, which could be material. |
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