Extract to table

Transferee Taxpayer Requirements Section 6418(a) provides that the transferee taxpayer must satisfy two conditions: (i) the transferee must not be "related" (within the meaning of Sections 267(b) or 707(b)(1)) to the eligible taxpayer, and (ii) the transferee must not be a "tax-exempt entity" as described in Section 168(h)(2) of the Code

Under the Proposed Regulations, the eligible taxpayer is required to complete a pre-filing registration process with the IRS prior to making the transfer election