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 June 3, 2025

Daniel B. Wolfe
Chief Executive Officer
Yukon New Parent, Inc.
c/o 180 Degree Capital Corp.
7 N. Willow Street, Suite 4B
Montclair, NJ 07042

 Re: Yukon New Parent, Inc.
 Amendment No. 1 to the Registration Statement on Form S-4
 Filed May 6, 2025
 File No. 333-286043
Dear Daniel B. Wolfe:

 We have reviewed your amended registration statement and have the
following
comments.

 Please respond to this letter by amending your registration statement
and providing
the requested information. If you do not believe a comment applies to your
facts and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

 After reviewing any amendment to your registration statement and the
information
you provide in response to this letter, we may have additional comments.

Form S-4 Filed May 6, 2025
Management of New Mount Logan, page 22

1. Please revise your disclosure to provide a clearer overview of who will
lead the
 combined company. In this regard, we note the reference on page 16 to
New Mount
 Logan relying on "BCPA and Key BCPA Personnel."
Risk Factors, page 36

2. Please disclose any material risks resulting from the deregistration of
180 Degree
 Capital as a business development company under the Investment Company
Act of
 1940. For example, it is unclear if key consequences of deregistration
may involve the
 loss of restrictions on affiliated transactions and self-dealing,
elimination of
 limitations on the use of leverage, etc.
 June 3, 2025
Page 2

3. Please revise to address the extent to which there is a material risk
that 180 Degree
 Capital or the combined company may not be successfully "excluded from
the
 definition of an investment company by Section 3(c)(1) or Section
3(c)(7) of the 1940
 Act," as referenced on page 10.
Sales of shares of New Mount Logan Common Stock after the completion, page 36

4. Please revise to disclose whether any lock-up agreements or resale
restrictions apply
 to shares issued in the merger. Quantify the number or percentage of
freely tradeable
 shares that could enter the market post-closing.
Regulations governing 180 Degree Capital's operation as a registered CEF, page
66

5. We note your disclosure that references limitations under the Investment
Company
 Act of 1940, including the 300% asset coverage requirement. We also note
that 180
 Degree Capital will deregister as a business development company in
connection with
 the merger. Please revise where appropriate to summarize the timeline
for
 transitioning between regulatory regimes and clarify the extent to which
the 300%
 requirement or 1940 Act requirements will continue to apply.
Background of the Mergers, page 111

6. We note your disclosure of a "Discount Management Program." Please
revise here or
 where appropriate to briefly describe such program and its purpose.
7. Please ensure your disclosure is clear about the persons involved in
negotiations
 or meetings. For example, where you refer to the "board" or
"management,"
 please clarify which members of the board were in attendance or
otherwise list the
 members in attendance.
8. We note your disclosure that initially a NAV-for-NAV transaction was
proposed but
 then was ultimately changed to a fixed value for Mount Logan that would
be adjusted
 by subsequent distributions, share issuances and certain debt refinance
expenses.
 Please expand your discussion as to clarify which party initiated the
change and how
 this change is expected to impact the consideration for each party to
the merger.
The Mergers
Mount Logan's Reasons for the Mergers, page 120

9. You state that Mount Logan "spent several years evaluating transactions
similar to the
 Business Combination" and concluded that this was the "best outcome" for
 shareholders. Please revise your disclosure to describe any alternative
transactions
 that were considered, and why they were rejected. If no specific
alternatives were
 formally evaluated, please disclose that fact.
180 Degree Capital's Reasons for the Mergers, page 124

10. We note the reference to the Mount Logan platform on page 124.
Please revise here
 and where appropriate to clarify what this term is meant to cover. For
example, is it
 restricted to Mount Logan, which has approximately $2.3 billion AUM, or
does it
 include BCPA and its affiliates, which collectively manage approximately
$40 billion
 of assets according to page 290.
 June 3, 2025
Page 3

11. Please revise here and where appropriate to explain how Mount Logan s
business
 model is highly complementary to 180 Degree Capital s business
model. Include a
 discussion of relevant, material factors regarding complementarity. For
example, it is
 unclear to what extent the entities have significantly different
geographic exposure,
 investor bases, type of fee-based models, type of fee generating
vehicles, size or
 nature of portfolio businesses, use of leverage, and so forth.
12. You state that the merger will enable "accelerated expansion of sourcing
 investments...through existing 180 Degree Capital relationships." Please
revise your
 disclosure to clarify what type of sourcing opportunities were
identified and how the
 Mount Logan Capital base enhances these opportunities.
Opinion of 180 Degree Capital's Financial Advisor, page 126

13. We note your disclosure on page 127 that Mount Logan Capital provided
financial
 projections to the 180 Degree Capital Special Committee and its
financial advisor in
 connection with the merger. However, the registration statement does not
include
 these projections or a summary thereof. Please revise your disclosure to
include these
 projections along with a description of the key assumptions underlying
them.
14. We note your disclosure on page 128 that the financial advisor to the
180 Degree
 Capital Special Committee reviewed certain closed-end fund merger
transactions as
 part of the fairness opinion. Please revise the disclosure to describe
the criteria used to
 select these transactions and explain why the selected transactions were
considered
 comparable. If any material differences exist between the precedent
transactions and
 the proposed merger, please explain. Similarly, we note the disclosure
on page 129
 that the financial advisor to 180 Degree Capital Special Committee
reviewed selected
 public companies comparable to Mount Logan Capital Inc. Please provide
equivalent
 disclosure for these comparable public companies. Similarly revise for
Mount Logan
 Capital's disclosures on pages 130 and 131.
15. We note that the majority of the implied equity values of Mount Logan
addressed by
 the financial advisor, Fenchurch, are higher than Mount Logan's $67.4
million
 transaction equity value agreed upon for the merger. As non-exclusive
examples, we
 note a $82 million to $121 million range of implied equity value for
2026 using
 trading comparables, a $76 million to $139 million range of implied
equity value for
 2025 using transactional analysis and an implied equity value of $104.5
million on
 January 1, 2025 using discounted cash flow. Please state whether the
board of Mount
 Logan considered these factors in arriving at its recommendation.
Regulatory Approvals and Related Matters, page 133

16. Please expand this section to clarify the status of required filings or
notices and the
 expected timing of remaining approvals. If material, address the
consequences or risks
 if the required approvals are delayed or not received.
The Merger Agreement
Merger Consideration, page 149

17. Please revise your disclosure to provide additional detail regarding the
in-kind
 distribution mechanism that may be used to reduce 180 Degree Capital's
NAV if its
 June 3, 2025
Page 4

 shareholders would otherwise receive more than 50% of the New Mount
Logan
 common stock. Specifically, please clarify:
 the types of assets that may be distributed in-kind;
 the methodology for selecting and valuing such assets;
 whether any shareholder consent or notice is required in connection
with the
 distribution; and
 when and how the determination will be made that a distribution is
required.

 Additionally, consider including a simplified numerical example to
illustrate how this
 mechanism could affect TURN's NAV and resulting ownership percentage in
the
 combined company.
Unaudited Pro Forma Combined Balance Sheet, page 177

18. Please revise your table on page 177 to include a subtotal for your
Asset Management
 total assets as of December 31, 2024 and ensure mathematical accuracy of
the
 information in the table.
19. We note your disclosure on page 179 that you present an adjustment to
total equity in
 the amount of $(11,829). Please revise your footnotes to include an
explanation and
 reconciliation for how this adjustment is calculated. In addition,
please ensure
 mathematical accuracy of your pro forma information. For example, it is
unclear as
 to how the adjustments to (i) total shareholders equity, (ii) total
equity and (iii) total
 liabilities and equity foot.
Unaudited Pro Forma Condensed Combined Statement of Operations, page 180

20. We note your presentation of Net Income (Loss) Attributable to Mount
Logan Capital
 Inc. Per Share of Common Shares and Weighted Average Shares of Common
Shares
 Outstanding. Please revise your disclosures to include adjustments and
footnotes
 explaining how you calculated the pro forma amounts compared from
historical. For
 example, explain how you considered all of the Mount Logan RSUs that
will have
 been vested upon completion of the merger in your calculation,
adjustments and
 presentation.
21. Please ensure the mathematical accuracy of the your pro forma statement
of
 operations for all columns and rows. For example, it is unclear as to
how the Income
 (loss) before income taxes and net income (loss) lines cross-foot and
the pro forma
 adjustments column does not appear to foot.
Notes to Unaudited Pro Forma Condensed Combined Financial Information
Note 1 - Basis of Pro Forma Presentation, page 184

22. We note the amounts disclosed on page 185 for the change in control
liabilities and
 business combination-related expenses of $2,107 and $5,577,
respectively, differ from
 those disclosed in footnote 3(B) on page 186. Please explain this
discrepancy and
 revise your disclosure to clarify accordingly.
 June 3, 2025
Page 5
Compensation and Benefits, page 265

23. We note your disclosure that Mount Logan s compensation arrangements
with certain
 employees contain a significant performance-based incentive component.
Please
 revise to disclose the terms of the performance-based incentive
compensation and
 how it is determined. To the extent applicable, discuss any
circumstances
 where incentive fees could be subject to clawback provisions.
Results of Operations, page 270

24. Please revise to further clarify the reasons underlying the 149%
increase in incentive
 fees, as disclosed on page 270.
Asset Management Segment
Revenues, page 271

25. We note the $1.9 million increase in OCIF incentive fees from 2023 to
2024 due to
 improved fund performance in 2024 compared to 2023. Please expand your
disclosure
 to provide further discussion of the factors or holdings contributing to
the improved
 fund performance. In addition, clarify if these were realized incentives
fees.
Assets Under Management, page 275

26. Please revise to include a roll-forward of assets under management by
fee generating
 vehicle showing inflows, outflows, market/asset appreciation, and if
material the
 effects of foreign currency translation. In addition, include
discussion, quantification
 and trends in your fee rates or weighted average fee rates by vehicle
over the periods
 presented.
Management's Discussion and Analysis of Financial Condition
Liquidity and Capital Resources, page 277

27. Please revise the discussion of Mount Logan s liquidity outlook to
address the
 negative cash flows from operations and investing activities.
Certain Relationships and Related Person, page 289

28. We note the statement on page 289 that BCPA owns a minority interest in
Mount
 Logan, as well as the statement on page 290 that Mount Logan s senior
management
 team "is comprised of substantially the same personnel as the senior
management
 team of BCPA." Please advise us why BCPA is not reflected in the
ownership table
 on page 313. Additionally, please revise this section to disclose, with
quantification,
 the material terms of the Servicing, Staffing, Senior Management and
other
 agreements. In this regard, please file such agreements as exhibits.
Management's Discussion and Analysis of Financial Condition
Results of Operations, page 302

29. We note your statement that owing to the structure and objectives of 180
Degree
 Capital's business you generally expect to experience net investment
losses and seek
 to generate increases in net assets from operations through long-term
appreciation.
 Please revise, where appropriate, to clarify the reasons for expected
net investment
 losses and how in light of net investment losses, increases in net
assets from
 June 3, 2025
Page 6

 operations can be achieved.
30. We note you attribute the increase in investment income for the year
ended December
 31, 2024 to receipt of board fees. Please revise, where appropriate, to
discuss in more
 detail these board fees. Address the following:
 Generally discuss whether or not board fees are contractually
governed and how
 they are determined, including the timing and amounts.
 Clarify whether 180 Degree Capital employees, such as Mr. Rendino,
receive
 any other payments outside of those remitted to 180 Degree Capital
in their roles
 as Board members of your portfolio companies.
 Generally discuss the form and quantify the portions of board fees
that are paid in
 cash and stock grants.
 Clarify whether the board fees are subject to clawback and under
what
 circumstances if so.
31. We note the statement on page 300 that 180 Degree Capital does not
believe the
 increase or decrease in the value of its investments materially impacts
its day-to-day
 operations or its daily liquidity. Please revise to clarify what
factors do materially
 impact 180 Degree Capital s liquidity.
32. We note your disclosure on page 303 that professional fees increased
75.1% for the
 year ended December 31, 2024 as compared with the year ended December
31, 2023,
 primarily as a result of an increase in legal expenses related to the
proposed Business
 Combination. Please revise here or where appropriate to discuss details
regarding the
 nature of the professional fees. In addition, include quantification
disaggregation
 expense amounts relating to the business combination activities as
opposed to normal,
 recurring professional fees, if any.
Mount Logan Capital Inc.
Notes to Consolidated Financial Statements
Note 2. Basis of Presentation
Goodwill, page F-21

33. We note goodwill of $55,697 relating to your Insurance Solutions
reportable segment,
 which includes two reporting units: long-term care insurance ( LTC )
and multi-year
 guaranteed annuity products ( MYGA ). We also note your disclosure
on page F-83
 that you have a concentration of revenue from the MYGA product line,
which are
 assumed solely from two insurance companies, ACL and SSL. Further, we
note that
 you made a decision to no longer assume business from ACL and SSL as of
June 30,
 2024. Please provide us with a summary of your goodwill impairment
analysis,
 specifically as it relates to your MYGA reporting unit. Please include
the following
 details in your response:
 the percentage by which fair value exceeded carrying value as of the
date of the
 most recent test;
 the amount of goodwill allocated to the reporting units;
 a description of the methods and key assumptions used and how the
key
 assumptions were determined, including those assumptions relating to
your
 revenue from the MYGA product line after June 30, 2024; and
 June 3