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INCOME TAX
 12 Months Ended
Dec. 31, 2024
Income Tax Disclosure [Abstract]  
INCOME TAX INCOME TAX
The Fund intends to elect to be treated for U.S. federal income tax purposes as a RIC under Subchapter M of the Code for the fiscal year ended December 31, 2024. As a result, the Fund generally must timely distribute substantially all of its net taxable income each tax year as dividends to its shareholders. Accordingly, no provision for U.S. federal income tax has been made in the consolidated financial statements.
The Fund will file income tax returns in U.S. federal and applicable state and local jurisdictions. The Fund’s U.S. federal income tax return is generally subject to examination for a period of three fiscal years after being filed. State and local tax returns may be subject to examination for an additional period of time depending on the jurisdiction. Management has analyzed the Funds’s tax positions taken for the open tax year and has concluded that no provision for income tax is required in the Fund’s consolidated financial statements.
Taxable income generally differs from net increase (decrease) in net assets resulting from operations for financial reporting purposes due to the timing of temporary and permanent differences in the recognition of gains and losses on investment transactions. Temporary differences do not require reclassification. As of December 31, 2024, permanent differences that resulted in reclassifications among the components of net assets resulting from operations relate primarily to paydowns, amendment fees, investments in partnerships, and non-deductible excise tax. Temporary and permanent differences have no impact on the Fund’s net assets.
As of December 31, 2024, 2023, and 2022, the Fund’s cost of investments for U.S. federal income tax purposes and gross unrealized appreciation and depreciation on investments were as follows:
December 31, 2024December 31, 2023December 31, 2022
Tax cost of investments$1,687,581 $516,168 $352,998 
Gross unrealized appreciation on investments8,216 3,128 1,389 
Gross unrealized depreciation on investments(14,188)(7,260)(4,869)
Net unrealized appreciation (depreciation) on investments$(5,972)$(4,132)$(3,480)
For the taxable years ended December 31, 2024, 2023, and 2022, the components of Accumulated Earnings (Losses) on a tax basis were as follows:
December 31, 2024December 31, 2023December 31, 2022
Undistributed ordinary income, net$5,889 $884 $370 
Undistributed long-term income, net975 634 — 
Total undistributed earnings$6,864 $1,518 $370 
Capital loss carryforward$— $— $(88)
Unrealized appreciation (depreciation), net(5,972)(4,194)(3,480)
Other book-to-tax differences(30)123 — 
Total accumulated earnings (losses), net$863 $(2,553)$(3,198)
Capital losses in excess of capital gains earned in a tax year generally may be carried forward and used to offset capital gains, subject to certain limitations. Under the Regulated Investment Company Modernization Act of 2010, capital losses incurred after September 30, 2011 will not be subject to expiration. As of December 31, 2024, the Fund did not have a capital loss carryforward available for use in future tax years.
For income tax purposes, dividends paid and distributions made to the Fund's shareholders are reported by the Fund to the shareholders as ordinary income, capital gains, or a combination thereof. The tax character of the distributions paid for the years ended December 31, 2024, 2023, and for the the period from February 8, 2022 (inception) through December 31, 2022 was as follows:
December 31, 2024December 31, 2023December 31, 2022
Distributions paid from:
Ordinary income$66,503 $33,890 $16,179 
Net long-term capital gains655 — — 
Total taxable distributions$67,158 $33,890 $16,179 
The Fund is subject to a 4% nondeductible federal excise tax on certain undistributed income unless the Fund distributes, in a timely manner as required by the Code, an amount at least equal to the sum of (1) 98% of its respective net ordinary income earned for the calendar year and (2) 98.2% of its respective capital gain net income for the one-year period ending October 31 in the calendar year. For the years ended December 31, 2024, 2023, and for the the period from February 8, 2022 (inception) through December 31, 2022, the Fund incurred $202, $31, and $2, respectively, in excise tax expense.
The Fund’s wholly owned subsidiary, Equity Holdings, is subject to U.S. federal and state corporate-level income taxes. As a result the Fund recorded a net deferred tax liability related to US GAAP to tax outside basis differences in Equity Holdings’ investments in certain partnership interests of $29 as of December 31, 2024, which are included in accounts payable and accrued expenses in the accompanying consolidated statements of assets and liabilities. For the year ended December 31, 2024, the Fund recorded a net tax benefit of $32. For the year ended December 31, 2023, the Fund recorded a net tax provision of $61. For the period from February 8, 2022 (inception) through December 31, 2022, the Fund did not record net tax benefit (provision).
The Fund accounts for income taxes in conformity with ASC Topic 740, Income Taxes ("ASC 740"). ASC 740 provides guidelines for how uncertain tax positions should be recognized, measured, presented and disclosed in the financial statements. ASC 740 requires the evaluation of tax positions taken in the course of preparing the Fund’s tax returns 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 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 Fund has concluded that it does not have any uncertain tax positions that met the recognition or measurement criteria of ASC 740.