Part III. Administrative, Procedural, and Miscellaneous

cating the built-in gain under section 704(c). The value of other contributed property must be aggregated by category on a statement attached to Form 926 (with, in each case, a brief description of the property). The categories are:

(1) Stock in trade of the transferor (inventory);

(2) Tangible property (other than stock in trade) used in a trade or business of the transferor;

(3) Cash, stock, notes receivable and payable, and other securities; and,

(4) Other property. Until further notice, taxpayers transferring property to partnerships will be required to report under section 6038B only section 721 contributions. Any guidance exercising the authority to require the reporting of other contributions will be prospective only. Additionally, Section 761(a) allows certain organizations that would otherwise be treated as partnerships to elect not to be treated as partnerships for purposes of subchapter K of the Code. Until further notice, any transfer to a foreign partnership with a valid section 761(a) election in effect will not be required to be reported under section 6038B.