(i), year 1 shall begin on the first day of the taxable year in which the facility with respect to which a credit was allowed under this subsection was placed in service. (C) Recapture event For purposes of this paragraph— (i) In general A recapture event occurs with respect to any facility if— (I) the taxpayer becomes insolvent, or (II) the taxpayer disposes of the facility to another person who, at this time of the disposition, is not an eligible business. (ii) Special rule for facilities not placed in service within 5 years In the case of a facility with respect to which a credit is allowed under this section which is not placed in service before the close of the 5th taxable year beginning after the first taxable year for which the credit was so allowed, a recapture event shall be treated as having occurred with respect to such facility in year 1. (2) Credit may be assigned The amount of qualified facility construction expenditures with respect to a facility which would (but for this paragraph) be taken into account under subsection (a) for any taxable year by any person (hereafter in this paragraph referred to as the initial taxpayer )— (A) may be taken into account by any other person to whom such expenditures are assigned by the initial taxpayer, and (B) shall not be taken to account by initial taxpayer. Any person to whom such expenditures are assigned under subparagraph (A) shall be treated for purposes of this title as the taxpayer with respect to such expenditures. (3) Controlled group All members of the same controlled group of corporations (within the meaning of section 52(a)) and all persons under common control (within the meaning of section 52(b)) shall be treated as 1 person for purposes of this section. (4) Predecessor Any reference in this section to a corporation or partnership shall include a reference to any predecessor of such corporation or partnership. (5) Denial of double benefit For purposes of this subtitle, if a credit is allowed under this section in connection with any expenditure