this subclause applies A trust is described in this subclause if such trust not described in subparagraph (A), the assets of such trust are not attributable to a gratuitous transfer of assets by a person who is subject to tax under this chapter for the calendar year, and such trust has a single beneficiary (determined as of the last day of the calendar year). (C) Right of recovery (i) In general If any part of the net value of taxable assets of an individual on which tax has been paid consists of the value of property held by a trust which is included in the net value of taxable assets of such individual by reason of subparagraph (B), then such individual shall be entitled to recover from the trust the amount which bears the same ratio to the recoverable amount as— (I) the value of such property, bears to (II) the net value of taxable assets of the taxpayer. (ii) Recoverable amount For purposes of clause (i), the recoverable amount with respect to any trust is the excess of— (I) the tax imposed under this chapter for the calendar year on the individual, over (II) the amount of such tax which would be imposed for such calendar year on such individual if no property held by such trust were included in the net value of taxable assets of the individual. (iii) Treatment where no recovery In any case where a trust does not reimburse any taxpayer as provided in clause (i), the taxpayer shall be treated for purposes of this chapter as having made a gratuitous transfer to the trust in an amount equal to the amount determined under clause (i). Such transfer shall be treated as having been made on the last day of the calendar year for which the tax under subsection (a) was due. (4) Treatment of assets held by certain split-interest trusts (A) Remainder interests in charitable remainder annuity trusts and charitable remainder unitrusts In the case of any charitable remainder annuity trust (as defined in section 664(d)(1)) or of a charitable remainder unitrust (as defined in section 664(d)(2))— (i) the present value of any