I also don't have an answer for you, but I would not expect this to generate a notice. I know that doesn't help finalize it, but I wouldn't worry about a notice and just deal with it if one comes.

I would get an 8821 in place on the client(s) so you get a copy of the notice as well if one comes so that you don't have to rely on the client to provide it to you. I'm starting to make that my default on clients now.