Andersen Managing Director Joe Calianno’s article OB3 – A Shift in How the Pro Rata Share Rules of IRC 965(a) Operate is included in New York University’s (NYU) 84^th Institute on Federal Taxation, 84 NYU IFT (May/June LexisNexis Mathew Bender). Joe is with Andersen’s US National Tax (USNT) Practice in the Washington, D.C. office and serves as USNT’s leader for international tax.