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Income Taxes
12 Months Ended
Dec. 31, 2024
Income Tax Disclosure [Abstract]  
Income Taxes

Note 9. Income Taxes

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 exited investments; and (3) 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 additional paid in capital, undistributed net investment income or undistributed net realized gains on investments, as appropriate. For the years ended December 31, 2024, December 31, 2023 and December 31, 2022 permanent differences were as follows:

 

 

For the Year Ended December 31,

 

 

 

2024

 

 

2023

 

 

2022(1)

 

Undistributed net investment income (loss)

 

$

4,936,037

 

 

$

488,192

 

 

$

 

Accumulated net realized gain (loss)

 

 

(3,809,061

)

 

 

(57,473

)

 

 

 

Paid In Capital

 

$

(1,126,976

)

 

$

(430,719

)

 

$

 

(1)
For the period from February 10, 2022 (date of inception) to December 31, 2022.

 

During the year ended December 31, 2024 permanent differences were principally related to non-deductible offering costs and the tax treatment of underlying fund investments.

 

The following reconciles the increase in net assets resulting from operations to taxable income for the years ended December 31, 2024, December 31, 2023 and December 31, 2022:

 

 

For the Year Ended December 31,

 

 

 

2024

 

 

2023

 

 

2022(1)

 

Net increase (decrease) in net assets resulting from operations

 

$

32,885,958

 

 

$

20,364,991

 

 

$

 

Net unrealized (appreciation) depreciation

 

 

1,420,961

 

 

 

(7,155,205

)

 

 

 

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

 

 

436,978

 

 

 

(346,768

)

 

 

 

Non-deductible capital gains incentive fee

 

 

68,298

 

 

 

1,090,162

 

 

 

 

Other timing differences and non-deductible expenses

 

 

1,443,321

 

 

 

428,374

 

 

 

 

Realized losses for tax not recognized

 

 

 

 

 

 

 

 

 

Total Taxable/distributable income

 

$

36,255,516

 

 

$

14,381,554

 

 

$

 

(1)
For the period from February 10, 2022 (date of inception) to December 31, 2022.

 

The components of accumulated gains / losses as calculated on a tax basis for the taxable years ended December 31, 2024, December 31, 2023 and December 31, 2022 were as follows:

 

 

For the Year Ended December 31,

 

 

 

2024

 

 

2023

 

 

2022(1)

 

Distributable ordinary income

 

 

 

 

 

1,161,852

 

 

 

 

Post October Loss Referral

 

 

(90,210

)

 

 

 

 

 

 

Other temporary book/tax differences

 

 

(2,776,669

)

 

 

(1,087,817

)

 

 

 

Net unrealized appreciation/(depreciation) on investments

 

 

5,780,278

 

 

 

7,501,973

 

 

 

 

Total accumulated under-distributed (over-distributed) earnings

 

 

2,913,399

 

 

 

7,576,008

 

 

 

 

(1)
For the period from February 10, 2022 (date of inception) to December 31, 2022.

 

Net capital losses recognized by the Company may be carried forward indefinitely and will retain their character as short‐term and/or long‐term losses. Any such losses will be deemed to arise on the first day of the next taxable year. Capital losses for the year ended December 31, 2024, which will be deemed to arise on the first day of the tax year ended December 31, 2024, December 31, 2023 and December 31, 2022, were as follows:

 

 

For the Year Ended December 31,

 

 

 

2024

 

 

2023

 

 

2022(1)

 

Capital loss carryforward

 

$

 

 

$

 

 

$

 

(1)
For the period from February 10, 2022 (date of inception) to December 31, 2022.

 

The cost and unrealized gain (loss) of the Company’s investments, as calculated on a tax basis, for the years ended December 31, 2024, December 31, 2023 and December 31, 2022, were as follows:

 

 

For the Year Ended December 31,

 

 

 

2024

 

 

2023

 

 

2022(1)

 

Gross unrealized appreciation

 

 

10,405,239

 

 

 

7,895,221

 

 

 

 

Gross unrealized depreciation

 

 

(4,623,105

)

 

 

(393,248

)

 

 

 

Net unrealized appreciation (depreciation) earnings

 

$

5,782,134

 

 

$

7,501,973

 

 

$

 

 

 

 

 

 

 

 

 

 

 

Tax cost of investments

 

$

750,741,197

 

 

$

344,876,547

 

 

$

 

(1)
For the period from February 10, 2022 (date of inception) to December 31, 2022.

 

The difference between GAAP-basis and tax basis unrealized gains (losses) is attributable primarily to differences in the tax treatment of underlying fund investments.

 

Of the dividends declared during the years ended December 31, 2024 and December 31 2023, $37,643,919 and $13,219,702 were derived from ordinary income, and $1,031,624 and $0 from long-term capital gain as determined on a tax basis.

KLCC SPV GS1 LLC, a wholly owned subsidiary formed in 2023, is a Delaware limited liability company which has elected to be treated as a corporation for U.S. tax purposes. As such, KLCC SPV GS1 LLC is subject to U.S. Federal, state and local taxes. For the Company’s tax year ended December 31, 2024, KLCC SPV GS1 LLC activity did not result in a material provision for income taxes.

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