Andersen Managing Director Joe Calianno’s comments are featured in the recent Tax Notes article, IRS’s Pro Rata Share Rules Set Up Compliance Headache. The article focuses on the documentation requirement in the transition rule for Sec. 951(a)(2)(B) relating to the new subpart F pro rata share rules under the One Big Beautiful Bill Act of 2025 as set forth in Notice 2025-75. One of the compliance challenges is the documentation requirement outlined in the guidance for establishing that a dividend increases a U.S. individual’s taxable income. The notice instructs taxpayers to determine and document the effect of the dividend by attaching a statement for Form 5471, Information Return of U.S. Persons With Respect to Certain Foreign Corporations. The statement must detail the amount of each dividend paid by a controlled foreign corporation (CFC) subject to the transition rule but treated as a dividend for purposes of the pro rata share rules and explain why the shareholder filing the return is entitled to treat those amounts as a dividend. Joe told Tax Notes that he understood why Treasury believed it needed to include the documentation rule, but added that it may be challenging for some taxpayers to comply because buyers will need to prove that the dividend increased the seller’s taxable income as provided in the notice. It adds a compliance burden for the U.S. buyer, Joe said.