Requirements
(ii) Requirements. A transaction satisfies the requirements of this paragraph (c)(1)(ii) if (A) The transferee member's acquisition of the eligible property meets the requirements of 1.168(k)-2(b)(3)(iii)(A) without regard to section 179(d)(2)(A) or (B) and 1.179-4(c)(1)(ii) or (iii) or the Group Prior Use Rule; (B) As part of the same series of related transactions that includes the acquisition, the transferee member ceases to be a member of the consolidated group and ceases to be related, within the meaning of section 179(d)(2)(A) or (B) and 1.179-4(c)(1)(ii) or (iii), to the transferor member; and (C) The acquired eligible property continues to be eligible property on the deconsolidation date and the day after the deconsolidation date. (2) Deemed acquisition of eligible property pursuant to an election under section 338 or 336(e) by a member that leaves the group(i) General rule (Consolidated Deemed Acquisition Rule). This paragraph (c)(2) applies to certain transactions pursuant to which a transferee member acquires from a transferor member the stock of another member of the same consolidated group that holds eligible property (target) in either a qualified stock purchase for which a section 338 election is made or a qualified stock disposition described in 1.336-2(b)(1) for which a section 336(e) election is made. Except as otherwise provided in paragraph (c)(3) or (4) of this section, if a transaction satisfies the requirements of paragraph (c)(2)(ii) of this section, then 1.168(k)-2(b)(3)(iii)(C) does not apply to the transaction, and for all Federal income tax purposes (A) The target is treated as selling the eligible property to an unrelated person on the day after the deconsolidation date in exchange for an amount of cash equal to the deemed sale amount; and (B) Immediately after the deemed sale in paragraph (c)(2)(i)(A) of this section, the target is treated as purchasing deemed replacement property from an unrelated person for an amount of cash equal to the deemed sale amount. (ii) Requirements. A transaction satisfies the requirements of this paragraph (c)(2)(ii) if: (A) The target's acquisition of the eligible property meets the requirements of 1.168(k)-2(b)(3)(iii)(A) without regard to the Group Prior Use Rule; (B) As part of the same series of related transactions that includes the qualified stock purchase or qualified stock disposition, the transferee member and the target cease to be members of the transferor member's consolidated group and cease to be related, within the meaning of section 179(d)(2)(A) or (B) and 1.179-4(c)(1)(ii) or (iii), to the transferor member; and (C) The target's eligible property on the acquisition date (within the meaning of 1.338-2(c)(1)) or the disposition date (within the meaning of 1.336-1(b)(8)) continues to be eligible property on the deconsolidation date and the day after the deconsolidation date. (3) Disposition of depreciable property pursuant to the same series of related transactions. Paragraph (c)(1) of this section does not apply if, following the acquisition of eligible property, the transferee member disposes of such property pursuant to the same series of related transactions that includes the property acquisition. Paragraph (c)(2) of this section does not apply if, following the deemed acquisition of eligible property, the target disposes of such property pursuant to the same series of related transactions that includes the qualified stock purchase or qualified stock disposition. See 1.168(k)-2(b)(3)(iii)(C) for rules regarding the transfer of property in a series of related transactions. See also 1.168(k)-2(g)(1) for rules regarding property placed in service and disposed of in the same taxable year. For purposes of this paragraph (c)(3), the deemed sale of eligible property by the transferee member or the target pursuant to paragraph (c)(1)(i)(A) or (c)(2)(i)(A) of this section is not treated as a disposition of such property. (4) Election to not apply paragraph (c)(1)(i) or (c)(2)(i) of this section(i) In general. If a transaction satisfies the requirements of the Consolidated Asset Acquisition Rule or the Consolidated Deemed Acquisition Rule in paragraph (c)(1)(ii) or (c)(2)(ii) of this section, respectively, the transferee member or the target nonetheless may elect not to apply the Consolidated Asset Acquisition Rule or the Consolidated Deemed Acquisition Rule, respectively, to all eligible property that is acquired or deemed acquired in such transaction. If a transferee member or target makes an election under this paragraph (c)(4) with respect to any transaction (designated transaction), then (A) The transferee member or target is deemed to have made such an election for all other transactions