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Income Taxes
12 Months Ended
Dec. 31, 2023
Income Tax Disclosure [Abstract]  
Income Taxes
8.
Income Taxes

The Company has elected to be regulated as a BDC under the 1940 Act and to be treated as a RIC under the Code and has made such an election beginning with the taxable year ending December 31, 2022. 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 Unitholders 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.

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, 2023 and 2022, the Company’s aggregate investment unrealized appreciation and depreciation for federal income tax purposes were as follows:

 

 

 

As of December 31,

 

 

2023

 

 

2022

 

Cost of investments for federal income tax purposes

 

$

156,354

 

 

$

47,564

 

Unrealized appreciation

 

$

1,408

 

 

$

 

Unrealized depreciation

 

$

(472

)

 

$

(1

)

Net unrealized appreciation (depreciation) on investments

 

$

936

 

 

$

(1

)

 

The following reclassifications have been made for the permanent difference between book and tax accounting as of December 31, 2023 and 2022. These differences result primarily from net operating losses, differences in accounting for partnership interest, and amendment fees reclassified as capital gains:

 

 

 

As of December 31,

 

 

 

2023

 

 

2022

 

Common Unitholders tax reclassification

 

$

 

 

$

(287

)

Undistributed net investment (loss) income

 

$

 

 

$

287

 

Accumulated net realized gain (loss)

 

$

 

 

$

 

The tax character of shareholder distributions attributable to the year ended December 31, 2023 and for the period from July 21, 2022 (Inception) to December 31, 2022 were as follows:

 

 

 

For the year ended December 31,

 

 

For the period from July 21, 2022 (Inception) to December 31,

 

 

 

2023

 

 

2022

 

Ordinary income

 

$

7,496

 

 

$

 

Return of capital

 

$

5,997

 

 

$

 

 

8.
Income Taxes (Continued)

The tax components of distributable earnings on a tax basis for the year ended December 31, 2023 and for the period from July 21, 2022 (Inception) to December 31, 2022 were as follows:

 

 

 

For the year ended December 31,

 

 

For the period from July 21, 2022 (Inception) to December 31,

 

 

 

2023

 

 

2022

 

Net tax appreciation (depreciation)

 

$

721

 

 

$

(1

)

Capital loss carryover

 

$

 

 

$

 

Other cumulative effect of timing differences

 

$

(1,303

)

 

$

(143

)

As of December 31, 2023, the Company had a short-term capital loss carryforward of $0.

The Company did not have any unrecognized tax benefits as of December 31, 2023 and 2022, nor were there any increases or decreases in unrecognized tax benefits for the period then ended; therefore, no interest or penalties were accrued.