taxpayer is a beneficial owner of the security transferred in such covered transaction. (b) Special rule If the tax imposed under section 4475(a) with respect to any covered transaction is paid by any person other than 1 or more beneficial owners of the security transferred in such covered transaction, the determination for how such tax is allocated to such beneficial owners shall be made in a reasonable manner not inconsistent with regulations or other guidance prescribed by the Secretary. (c) Limitation based on modified adjusted gross income (1) In general Subsection (a) shall not apply to a taxpayer for the taxable year if the modified adjusted gross income of the taxpayer for the taxable year exceeds $50,000 ($75,000 in the case of a joint return and one-half of such amount in the case of a married individual filing a separate return). (2) Modified adjusted gross income For purposes of paragraph (1), the term modified adjusted gross income means adjusted gross income— (A) determined without regard to sections 86, 893, 911, 931, and 933, and (B) increased by the amount of interest received or accrued by the taxpayer during the taxable year which is exempt from tax. (3) Inflation adjustment (A) In general In the case of any taxable year beginning after 2024, each dollar amount referred to in paragraph (1) shall be increased by an amount equal to— (i) such dollar amount, multiplied by (ii) the cost-of-living adjustment determined under section (1)(f)(3) of the Internal Revenue Code of 1986 for the calendar year in which the taxable year begins, by substituting 2023 for 2016 in subparagraph (A)(ii) thereof. (B) Rounding If any amount as adjusted under subparagraph (A) is not a multiple of $50, such amount shall be rounded to the nearest multiple of $50. (d) Eligible individual (1) In general The term eligible individual means, with respect to any taxable year, an individual who— (A) has attained the age of 18 as of the last day of such taxable year, and (B) is a citizen or lawful permanent resident (within the