not be taken into account if— (i) the value of the stock transferred is commensurate with the amount of capital being contributed, and (ii) such exchange is not part of a plan to redeem other shareholders. (B) Aggregate limitation The aggregate amount of net operating loss or net operating loss carryover for which an advance refund is elected pursuant to this subsection shall not exceed $100,000,000. (C) Reduction of net operating loss The net operating losses of the taxpayer determined under subsection (c) shall be reduced by the amount of any net operating loss or net operating loss carryover for which an advance refund is elected pursuant to this subsection, including the amount of any net operating loss to which paragraph (1)(C) applies. (D) Aggregation rule All corporations treated as a single employer under subsection (a) of section 52 or subsection (m) or (o) under section 414 shall be treated as a single taxpayer for purposes of this section. (5) Regulations and guidance The Secretary shall issue such regulations and other guidance as may be necessary to carry out the purposes of this section, including regulations and other guidance to carry out the purposes of this subsection— (A) to allow for the making of an election for the application of this subsection in such manner as the Secretary may by regulations prescribe, (B) to allow the payment of the advance refund in accordance with section 6429 based on such information as the Secretary shall require, (C) to allow advance refunds permitted under this subsection to be claimed on such forms as the Secretary shall prescribe, and (D) to provide for the application of this subsection to taxpayers that file consolidated returns. (6) Advance refund See section 6429 for rules for claiming the advance refund. . (2) Conforming amendment Section 172(c) of such Code is amended by inserting before the period at the end the following: and with the reduction required by subsection (g) . (b) Advance refund of research credits and orphan drug credits for C corporation