that the entity was under examination on or before May 8, 1996. The initial regulations also included a list of foreign entities which would always be classified as corporations ("per-se corporations") and which could not elect to be disregarded. The proposed regulations included naamloze vennootschap formed under the laws of Aruba or the Netherlands Antilles in that list, but they were removed from the final list; conversely, Canadian corporations were added to the list. In 1998, the IRS issued Notice 98–11, 1998-1 C.B. 433 in an attempt to combat the use of "check-the-box" in international tax planning (see below); however, the notice met opposition, and was withdrawn by Notice 98–35, 1998-2 C.B. 34. Another proposal, around 1999, would have left the basic check-the-box regime in place, but allowed the IRS to disregard entity classification elections made in connection with "extraordinary transactions" (where the tax liability changes "significantly" as a result of the election). An "extraordinary transaction" was defined as one in which there was a sale, exchange, transfer, or other disposition of a 10-percent or greater interest in a foreign entity; the proposed regulations provided that an election to be classified as a disregarded entity could be ignored, and thus the entity continue to be taxed as a corporation, if the election occurred within twelve months following the day before an extraordinary transaction. However, various tax professionals opposed the changes, arguing that the threshold for defining an extraordinary transaction was far too low, and that existing internal revenue regulations, as well as common law doctrines such as the principle of substance over form and the step transaction doctrine, were already sufficient to combat any abuses of the check-the-box rules. President Barack Obama attempted to revive the IRS' 1998 notice in his proposed 2010 budget. Specifically, the proposal stated: The proposal was eventually dropped again due to criticism from businesses, and it was not included again in the 2011 budget proposal either. References Corporate law Corporate taxation in the United States International taxation