JD Supra

IRS Previews Proposed Regulations On Pro Rata Share Transition Rule For Allocating Subpart F Income Inclusions

In furtherance of its efforts to provide guidance related to the implementation of tax law changes that are part of the One Big Beautiful Bill Act of 2025 (OBBBA), on December 4, 2025, the IRS issued ...
Florida Today

Business Q&A: If you have IRA questions, here's what to know about the pro-rata rule

Q. Hi Dan. In your last column you wrote about “… a rather infamous provision dubbed the ‘pro-rata rule.’” One of my IRAs is non-deductible, so I need to know what that is and why it’s infamous. Can ...
JD Supra

The End of Non-Pro Rata Uptiers? Fifth Circuit Rules that Serta Exchange was Not an “Open Market Purchase”

The United States Court of Appeals for the Fifth Circuit (the “Fifth Circuit”) ruled on December 31, 2024 that Serta Simmons Bedding’s (“SSB”) 2020 uptier exchange included a transaction that, ...
TechCrunch

Seed VCs are turning to new ‘pro rata’ funds that help them compete with the big firms

Lee Edwards, partner at Root VC, has a saying at his firm that “pro rata rights are earned, not given.” That may be a bit of a stretch since pro rata refers to a term that VCs put in their term sheets ...