You don't indicate what type of entity is involved, nor does your referenced article, but I would also take a look at the following CCA. While it does not reach a conclusion, due to limited facts, I believe this will provide some additional "comfort":
https://www.irs.gov/pub/irs-wd/1114025.pdf
Indirectly, I believe that it could lead to a conclusion that no reporting is required. But as noted above, your facts are also limited.
*A reminder that posts in a forum such as this do not constitute tax advice.
Also keep in mind the date of replies, as tax law changes.
