She admitted a high pro rata
is a difficult problem to overcome, but in many cases, such as with buildings with a block of sponsor units on the market, arrangements can be made.
Yet, few would disagree the pro rata
allocation approach is inappropriate for the transactions addressed by the EITF consensus and that the relative fair value cost allocation approach generates a preferable accounting result.
These sections state that a shareholder's gross income includes his pro rata
share of the S income and the character of any item included in the pro rata
share will be determined as if the item were realized directly by the shareholder from the source from which it was realized by the corporation.
Planning idea: The debt issuer may use the new pro rata
prepayment provision to accelerate income or deductible premium, depending on the terms of the instrument and the current interest rate market, by prepaying part of the outstanding obligation.
On a calendar year basis, the Trustee will furnish to each beneficiary a statement of the beneficiary's pro rata
share of the items of income, gain, loss, credit and deduction of the Trust to be included on the beneficiary's tax returns, and a statement of the beneficiary's pro rata
share of the assets and liabilities of the Trust.
The shareholder may purge the PFIC taint by including in income as a dividend (treated as an excess distribution) his pro rata
share of the corporation's post-1986 earnings and profits.
in that event, the pro rata
method cannot be used, and the specific accounting method is required (rather than elective).
Upon the occurrence of a sequential pay event, principal will be paid on a sequential basis to all of the note classes and pro rata
between the class A-PT and class A-1 notes (class A-1A and A-1B paid sequentially).
In the event that any of these tests are not met, payments will be made on a pro rata
basis (except for the senior coverage test, pursuant to which payments are made first, to the class A-FP and A-1 notes and second, to the class A-FP and A-2 notes) to pay down the principal amount of the notes included in the coverage test until the failing coverage test is cured.
If this is exhausted, bonds are further secured by program reserves, and then by a pro rata
share of the other primary reserves within the indenture.
Payments made to the two E class notes and the two F class notes are pro rata
for both interest and principal payments.