Quarterly report [Sections 13 or 15(d)]

DIVIDENDS, DISTRIBUTIONS AND TAXABLE INCOME

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DIVIDENDS, DISTRIBUTIONS AND TAXABLE INCOME
 6 Months Ended
Jun. 30, 2025
Income Tax Disclosure [Abstract]  
DIVIDENDS, DISTRIBUTIONS AND TAXABLE INCOME DIVIDENDS, DISTRIBUTIONS AND TAXABLE INCOME
MSC Income currently accrues and pays regular quarterly dividends to its stockholders and expects to periodically accrue and pay supplemental quarterly dividends to its stockholders. Future dividends, if any, will be determined by its Board of Directors on a quarterly basis.
Summarized dividend information for the three and six months ended June 30, 2025 and 2024 is as follows:
Three Months Ended June 30, Six Months Ended June 30,
2025 2024 2025 2024
(in thousands, except per share amounts)
Regular quarterly dividends per share $ 0.35  $ 0.36  $ 0.70  $ 0.73 
Supplemental quarterly dividends per share 0.01  —  0.02  — 
Total dividends per share $ 0.36  $ 0.36  $ 0.72  $ 0.73 
Total regular quarterly dividends $ 16,502  $ 14,425  $ 32,900  $ 29,246 
Total supplemental quarterly dividends 472  —  940  — 
Total dividends
 $ 16,974  $ 14,425  $ 33,840  $ 29,246 
MSIF has elected to be treated for U.S. federal income tax purposes as a RIC. MSIF’s taxable income includes the taxable income generated by MSIF and certain of its subsidiaries, including the Structured Subsidiaries, which are treated as disregarded entities for tax purposes. As a RIC, MSIF generally will not pay corporate-level U.S. federal income taxes on any net ordinary taxable income or capital gains that MSIF distributes to its stockholders. MSIF must generally distribute at least 90% of its “investment company taxable income” (which is generally its net ordinary taxable income and realized net short-term capital gains in excess of realized net long-term capital losses) and 90% of its tax-exempt income to maintain its RIC status (pass-through tax treatment for amounts distributed). As part of maintaining RIC status, undistributed taxable income (subject to a 4% non-deductible U.S. federal excise tax) pertaining to a given fiscal year may be distributed up to twelve months subsequent to the end of that fiscal year, provided such dividends are declared on or prior to the later of (i) filing of the U.S. federal income tax return for the applicable fiscal year or (ii) the fifteenth day of the ninth month following the close of the year in which such taxable income was generated.
The determination of the tax attributes for MSC Income’s distributions is made annually, based upon its taxable income for the full year and distributions paid for the full year. Therefore, a determination made on an interim basis may not be representative of the actual tax attributes of distributions for a full year. Ordinary dividend distributions from a RIC do not qualify for the 20% maximum tax rate (plus a 3.8% Medicare surtax, if applicable) on dividend income from domestic corporations and qualified foreign corporations, except to the extent that the RIC received the income in the form
of qualifying dividends from domestic corporations and qualified foreign corporations. The tax attributes for distributions will generally include both ordinary income and qualified dividends, but may also include either one or both of capital gains and return of capital.
Listed below is a reconciliation of “Net increase in net assets resulting from operations” to taxable income and to total distributions declared to common stockholders for the six months ended June 30, 2025 and 2024.
Six Months Ended June 30,
2025 2024
(estimated, in thousands)
Net increase in net assets resulting from operations $ 32,164  $ 28,717 
Net unrealized appreciation (14,879) (5,093)
Income tax provision 522  3,717 
Pre-tax book income not consolidated for tax purposes (9,747) (7,543)
Book income and tax income differences, including debt origination, structuring fees, dividends, realized gains and changes in estimates 19,901  3,523 
Estimated taxable income (1) 27,961  23,321 
Taxable income earned in prior year and carried forward for distribution in current year 20,348  14,745 
Taxable income earned prior to period end and carried forward for distribution next period (31,443) (23,245)
Dividend payable as of period end and paid in the following period 16,974  14,425 
Total distributions accrued or paid to common stockholders $ 33,840  $ 29,246 
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(1)MSIF’s taxable income for each period is an estimate and will not be finally determined until MSIF files its tax return for each year. Therefore, the final taxable income, and the taxable income earned in each period and carried forward for distribution in the following period, may be different than this estimate.
The Taxable Subsidiaries primarily hold certain equity investments for MSC Income. The Taxable Subsidiaries permit MSC Income to hold equity investments in portfolio companies which are “pass-through” entities for tax purposes and to continue to comply with the “source-of-income” requirements contained in the RIC tax provisions of the Code. The Taxable Subsidiaries are consolidated with MSIF for U.S. GAAP financial reporting purposes, and the portfolio investments held by the Taxable Subsidiaries are included in MSC Income’s consolidated financial statements as portfolio investments and recorded at fair value. The Taxable Subsidiaries are not consolidated with MSIF for income tax purposes and may generate income tax expense, or benefit, and tax assets and liabilities, as a result of their ownership of certain portfolio investments. The taxable income, or loss, of the Taxable Subsidiaries may differ from their book income, or loss, due to temporary book and tax timing differences and permanent differences. The Taxable Subsidiaries are each taxed at corporate income tax rates based on their taxable income. The income tax expense, or benefit, if any, and the related tax assets and liabilities, of the Taxable Subsidiaries are reflected in MSC Income’s consolidated financial statements.
The income tax provision for MSC Income is generally composed of (i) deferred tax expense (benefit), which is primarily the result of the net activity relating to the portfolio investments held in the Taxable Subsidiaries, including changes in loss carryforwards, changes in net unrealized appreciation or depreciation and other temporary book tax differences, and (ii) current tax expense, which is primarily the result of current U.S. federal income and state taxes relating to net currently taxable activity relating to the portfolio investments held in the Taxable Subsidiaries and excise taxes on MSC Income’s estimated undistributed taxable income. The income tax expense, or benefit, and the related tax assets and liabilities generated by the Taxable Subsidiaries, if any, are reflected in MSC Income’s Consolidated Statements of Operations. MSC Income’s net investment income related taxes were comprised of the following for the three and six months ended June 30, 2025 and 2024:
Three Months Ended June 30, Six Months Ended June 30,
2025 2024 2025 2024
(in thousands)
Net investment income taxes
Current tax expense:
Federal $ 65  $ 125  $ 118  $ 178 
State and other
 103  212  342  414 
Excise 87  4  279  80 
Total current tax expense 255  341  739  672 
Deferred tax expense (benefit):
Federal 894  574  1,242  745 
State and other
 (150) 31  59  88 
Total deferred tax expense 744  605  1,301  833 
Total net investment income tax provision $ 999  $ 946  $ 2,040  $ 1,505 
Investment valuation related taxes
Current tax expense:
Federal $ —  $ 205  $ —  $ 205 
Total current tax expense —  205  —  205 
Deferred tax expense (benefit):
Federal 549  1,513  (1,413) 1,997 
State and other 344  112  (105) 10 
Total deferred tax expense (benefit) 893  1,625  (1,518) 2,007 
Total investment valuation related income tax provision (benefit) $ 893  $ 1,830  $ (1,518) $ 2,212 
Total income tax provision $ 1,892  $ 2,776  $ 522  $ 3,717 
The net deferred tax asset as of June 30, 2025 and December 31, 2024 was $0.8 million and $0.6 million, respectively, with the change primarily related to changes in net unrealized appreciation or depreciation, changes in loss carryforwards and other temporary book-tax differences relating to portfolio investments held by the Taxable Subsidiaries. As of June 30, 2025, for U.S. federal income tax purposes, the Taxable Subsidiaries did not have any net operating loss carryforwards. The Taxable Subsidiaries have net capital loss carryforwards from prior years which, if unused, will expire in various taxable years 2025 through 2029. Additionally, the Taxable Subsidiaries have interest expense limitation carryforwards which have an indefinite carryforward period.