Annual report pursuant to Section 13 and 15(d)

Income Taxes

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Income Taxes
 12 Months Ended
Dec. 31, 2023
Income Tax Disclosure [Abstract]  
Income Taxes 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; (3) income or loss recognition on foreign currency transactions; (4) significant debt modifications; and (5) 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, 2023 and 2022, permanent differences were as follows:
Year Ended December 31,
2023 2022
Undistributed net investment income (loss) $ (11,599) $ 9,805 
Accumulated net realized gain (loss) 14,866  (6,922)
Paid In Capital $ 3,267  $ 2,883 

During the years ended December 31, 2023 and 2022, permanent differences were principally related to non-deductible offering costs, market discount, and other nondeductible expenses.

The following reconciles the increase in net assets resulting from operations to taxable income for the years ended December 31, 2023 and 2022:
Year Ended December 31,
2023 2022
Net increase (decrease) in net assets resulting from operations $ 654,601  $ 58,947 
Net unrealized (appreciation) depreciation (214,133) 157,391 
Realized gain (loss) for tax not included in book income 5,497  1,621 
Other non-deductible expenses and excise taxes 3,267  2,884 
Other book/tax differences 33,473  (6,506)
Taxable income $ 482,705  $ 214,337 

The components of accumulated gains / losses as calculated on a tax basis for the years ended December 31, 2023 and 2022 were as follows:
Year Ended December 31,
2023 2022
Distributable ordinary income $ 34,049  $ 37,792 
Distributable capital gains/(losses) (20,701) (857)
Net unrealized appreciation/(depreciation) on investments 56,742  (157,391)
Total accumulated under-distributed (over-distributed) earnings $ 70,090  $ (120,456)

The cost and unrealized gain (loss) of the Company’s investments, as calculated on a tax basis, at December 31, 2023 and 2022 is as follows:
Year Ended December 31,
2023 2022
Gross unrealized appreciation $ 166,817  $ 71,292 
Gross unrealized depreciation (95,061) (222,079)
Net unrealized appreciation (depreciation) $ 71,756  $ (150,787)
Tax cost of investments $ 9,217,654  $ 5,853,583 

The difference between GAAP-basis and tax basis unrealized gains (losses) is attributable primarily to net mark to market gains (losses) on foreign currency contracts, market discount, and significant modification of debt securities.
Under the Regulated Investment Company Modernization Act of 2010, net capital losses recognized by the Company may get carried forward indefinitely, and 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, 2023 and 2022, which will be deemed to arise on the first day of the tax year ended December 31, 2024 and 2023, were as follows:

Year Ended December 31,
2023 2022
Short-term $ 3,650  $ — 
Long-term $ 9,892  $ — 

All of the distributions declared during the years ended December 31, 2023 and 2022 were derived from ordinary income, as determined on a tax basis and 86.94% and 89.7%, respectively, of distributed ordinary income qualified as interest related dividends which is exempt from U.S. withholding tax applicable to non-U.S. shareholders.

Management has analyzed the Company's tax positions taken, or to be taken, on federal income tax returns for all open tax years 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.