From: Rabbi Moshe Sofer
To: Rabbi Aharon Hirschman
A Jew sold a pregnant cow to a gentile landlord via a written contract alone, with no actual payment or valid kinyan performed. The Chasam Sofer rules the calf is a safek bechor and one may not be lenient, systematically rejecting arguments that a powerful gentile's capacity to seize property, forcible seizure, or a commercial contract alone suffice to create genuine gentile ownership — and therefore no exemption from the Torah-level obligation of bechor applies.
Source: Shu"t Chasam Sofer YD §315