By Grant Williams

As Congress eventually moves to consider making broad changes to the nation's tax structure, proposals could arise that would take into account a "blurring of the lines" in recent years between companies and nonprofit groups, says Russell Sullivan, staff director for the Senate Finance Committee.

"We might see the emergence of some proposals to establish what I'll call, for the lack of a better term, a for-benefit corporation," something in-between companies and charities, he told a symposium in Washington. (He said he was speaking only for himself and not for his boss, Max Baucus, the Montana Democrat who chairs the Senate Finance Committee, or the committee.)

As an example, Mr. Sullivan pointed to the new federal health-care law. "A lot of changes are coming in health care," he said. "One of them is we authorized these state-based cooperatives to sell insurance in their states. Not a public option, not pure private sector. So the question is, What is the purpose of that entity and how should it be taxed?"

Federal law already has rules regarding agricultural and other cooperatives, he noted, but Congress may want to look at handling "the advent of some of the new kinds of business entities we're seeing evolve."

Mr. Sullivan spoke at a symposium held by Catholic University's Columbus School of Law.