On 19 December 2008, the US Treasury Department and the IRS issued proposed regulations under the conduit financing provisions of Sec. 7701(l) of the Internal Revenue Code and Treasury Regulation Sec. 1.881-3, which address primarily financing arrangements that are effected through entities that are generally disregarded under US tax law, such as "check-the-box" branches. In general terms, the proposed regulations take the view that an entity that is generally disregarded for US tax purposes can nevertheless be a "person" for purposes of the conduit financing rules. This article considers the implications of the proposed regulations on US tax planning.