My recollection was that this is not a clear cut issue... I think it relates to a "relation-back" doctrine that has a split in the circuits. I know that I have researched this before, but its been a few years- I suggest researching again to check the current state of this law. My guess is that it is not resolved, and that there might be a possibility that you could take a position different from the one that is indicated above. Of course, whatever position you take for tax purposes you need to take for funding purposes.