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INCOME TAXES
 9 Months Ended
Sep. 30, 2026
Income Tax Disclosure [Abstract]  
INCOME TAXES INCOME TAXES
The Fund primarily generates its income within the U.S. The Fund has elected to be treated as a corporation for U.S. federal and state income tax purposes. As a result, U.S. federal and state tax will be assessed on the Fund’s net income.

For federal income tax purposes, the estimated cost of investments held on September 30, 2026 was $10,010.8 million. For all investments in which there was an excess of value over tax cost, there was $298.0 million in gross unrealized appreciation and $22.5 million in gross unrealized depreciation. For all investments in which there is an excess of tax cost over value, gross unrealized depreciation was $3.3 million. Overall net unrealized appreciation was $272.2 million. The excess value of investments over their estimated tax cost resulting from differences other than net unrealized appreciation (e.g. book versus tax treatment of distributions received from investments) was $283.9 million.

Income taxes are accounted for using the liability method of accounting. Under such method, deferred tax assets and liabilities are recognized for the expected future tax consequences of differences between the carrying amounts of assets and liabilities and their respective tax basis, using tax rates in effect for the year in which the differences are expected to reverse. The effect on deferred assets and liabilities of a change in tax rates is recognized as income in the period when the change is enacted. Deferred tax assets are reduced by a valuation allowance when it is more likely than not that some portion or all of the deferred tax assets will not be realized. Current and deferred tax liabilities are reflected on a net basis in the financial statements.
The provision for income taxes consists of the following for the three and nine months ended September 30, 2026 and 2025:
Three months ended September 30,Nine months ended September 30,
2026202520262025
Current
U.S. federal income tax (expense)/benefit$— $— $— $— 
State and local income tax (expense)/benefit— — — — 
— — — — 
Deferred
U.S. federal income tax (expense)/benefit(36,455)(8,509)(77,291)(15,790)
State and local income tax (expense)/benefit(6,970)(827)(18,386)(1,535)
(43,425)(9,336)(95,677)(17,325)
Total
U.S. federal income tax (expense)/benefit(36,455)(8,509)(77,291)(15,790)
State and local income tax (expense)/benefit(6,970)(827)(18,386)(1,535)
Income tax (expense)/benefit$(43,425)$(9,336)$(95,677)$(17,325)

The reconciliation of taxes from the statutory tax rate to the Fund’s effective tax rate as calculated in accordance with ASU 2023-09 for the nine months ended September 30, 2026 is presented below:
Nine months ended September 30, 2026
U.S. federal statutory tax rate21.0 %
State and local income taxes, net of federal income tax effect3.0 
Effect of changes in state tax laws or rates enacted in the current period 0.8 
Total effective rate24.8 %

The reconciliation of the statutory tax rate to the Fund’s effective tax rate for the period prior to the adoption of ASU 2023-09 for the nine months ended September 30, 2025 is as follows:
Nine months ended September 30, 2025
Income tax expense at federal statutory rate21.0 %
State income tax (net of federal benefit)1.6 
Total effective rate22.6 %
The income tax effects of temporary differences that give rise to significant portions of deferred tax assets and liabilities were as follows as of September 30, 2026 and December 31, 2025:
As of
September 30, 2026December 31, 2025
Deferred tax assets
Net operating loss$20,910 $1,880 
Interest expense1,646 2,765 
Incentive fees2,400 2,544 
Total gross deferred tax assets24,956 7,189 
Valuation allowance— — 
Total deferred tax assets24,956 7,189 
Deferred tax liabilities
Investments(1)
137,344 42,417 
Interest rate swaps(1)
19,208 692 
Total deferred tax liabilities156,552 43,109 
Net deferred tax (liabilities) assets$(131,596)$(35,920)
(1)Represents the tax impact of the difference in book and tax basis for investments and interest rate swaps.

In assessing the realizability of deferred tax assets, the Fund considers whether it is probable that some or all of the deferred tax assets will not be realized. In determining whether the deferred taxes are realizable, the Fund considers the period of expiration of the tax asset, historical and projected taxable income, and tax liabilities for the tax jurisdiction in which the tax asset is located. Valuation allowances are provided to reduce the amounts of deferred tax assets to an amount that is more likely than not to be realized based on an assessment of positive and negative evidence, including estimates of future taxable income necessary to realize future deductible amounts.
The Fund analyzes its tax filing positions in all U.S. federal, state and local tax jurisdictions where it is required to file income tax returns for all open tax years (2024 - 2026). The Fund recognizes the tax benefit from an uncertain tax position only if it is more likely than not that the tax position will be sustained upon examination by the taxing authorities based on the technical merits of the position. The tax benefit recognized in the financial statements for a particular tax position is based on the largest benefit that is more likely than not to be realized. The amount of unrecognized tax benefits (“UTBs”) is adjusted as appropriate for changes in facts and circumstances, such as significant amendments to existing tax law, new regulations or interpretations by the taxing authorities, new information obtained during a tax examination, or resolution of an examination.

The Fund recognizes both accrued interest and penalties, where appropriate, related to UTBs in general, administrative and other expenses.

Tax laws are complex and subject to different interpretations by the taxpayer and respective governmental taxing authorities. Significant judgment is required in determining tax expense and in evaluating tax positions, including evaluating uncertainties under GAAP. The Fund reviews its tax positions monthly and adjusts its tax balances as new information becomes available.

As of September 30, 2026 and December 31, 2025, the Fund had no significant uncertain tax positions.

The Fund files its tax returns as prescribed by the tax laws of the jurisdictions in which it operates. In the normal course of business, the Fund is subject to examination by federal, state and local tax regulators. As of September 30, 2026, the Fund is subject to potential examination by federal, state and local tax regulators for returns filed since the Fund’s inception in 2024.