Senior Counsel Fanny Karaman and Day Pitney partner Carl Merino co-authored “Proposed Regulations and the Pro Rata Share Rule for CFCs: Part I,” published in Trusts & Estates.
The article examines how recently published proposed regulations implementing the One Big Beautiful Bill Act of 2025’s changes to the pro rata share rule (the “Proposed Regulations”) will impact mergers and acquisitions. Part II will focus on their impact on post-mortem planning techniques for inbound succession planning structures. Read Part I
