SOME CHECK-THE-BOX DETAILS still remain to be worked out.

The US allows taxpayers wide latitude to designate companies as corporations or partnerships or ignore them altogether. Companies in the last category are called “disregarded entities.” There are still many unanswered questions, including whether mergers involving disregarded entities should be treated as tax-free mergers under the same rules that apply where all the entities involved in the merger are corporations. The New York State Bar Association sent Treasury a list of five fact patterns recently on which it asked for
guidance.