WHETHER TO FILE FORM 926 FOR A PARTNER IN A PARTNERSHIP

The client is an individual partner in a domestic partnership that contributed property to a wholly owned Canadian corporation in a transaction identified by the partnership as qualifying under §351. The K-1 supplemental disclosure identifies a $24 million cash contribution.   The client's ending partnership capital percentage is 0.31%, and the client has no other direct, indirect or family-related ownership or transfers involving the Canadian corporation.  The memorandum from the partnership states “Your pro-rata share of property contributions through the company may be reportable.  If you made any other direct or indirect contributions of cash to the Canadian corporation exceeding $100,000, or if you meet the percentage interest requirements you may be required to report these on form 926.  You will need to determine your pro-rata share accordingly”.  Using the K-1 .31%, the client is below the reporting threshold. Is this approach acceptable?