Rationale (October, 2009):

The description is intended as an aid to understanding the concepts, not as a literal transformation that is performed. An implementation is permitted to allocate a zero-length array, even if such as array cannot be decclared (e.g., via a new-expression).

The exposition of list initialization using an array in 9.4.5 [dcl.init.list] paragraph 4 raises the question of whether an empty initializer list is permitted, as declaration of an array with a zero bound is ill-formed.