of such Code is amended by inserting (other than amounts excluded from gross income under section 118) after exempt from tax under this title . (d) Conforming amendment The heading for section 118 of such Code is amended by striking of a corporation and inserting of corporations and partnerships . (e) Effective date The amendments made by this section shall apply to contributions made after the date of the enactment of this Act. (f) No inference Nothing contained in this section or the amendments made by this section shall be construed to create any inference under the Internal Revenue Code of 1986 with respect to the treatment of contributions to the capital of partnerships made on or before the date of the enactment of this Act.