net worth (as determined for purposes of this section) shall be— (i) increased by the value of such transferred asset at the time of transfer, (ii) decreased (but not in excess of the amount of the increase under clause (i)) by the amount paid in consideration for such asset by the transferee, (iii) in the case of any decrease under clause (ii), increased to the extent of any liability of the transferee to the transferor or related party (as defined under section 267(b)) of the transferor, incurred in connection with the transfer of such asset, to the extent that the right to collect such liability is not already reflected in the net wealth of the transferor, and (iv) increased by the value of any such transferred asset transferred with a purpose that was in substantial part to avoid tax, to the extent not already included as an increase under clause (i) or (iii). (B) Exceptions Subparagraph (A) shall not apply with respect to any transfer of an asset to— (i) an organization described in section 170(c), (ii) a spouse or former spouse if section 1041 applies to such transfer, or (iii) a spouse if both spouses are applicable taxpayers at the time of such transfer. (C) Special rule regarding transfer to avoid tax For purposes of subparagraph (A)(iv), if one or more transfers of assets would (but for this sentence) reduce the tax imposed under this section and the taxpayer retains a substantial degree of control over such assets, the purpose of such transfers shall be treated as avoidance of tax unless the taxpayer shows otherwise by clear and convincing evidence. (d) Minimum tax account balance For purposes of this section, the term minimum tax account balance means, with respect to any taxpayer for any taxable year, the excess (if any) of— (1) the aggregate amount of tax imposed under this section with respect to the taxpayer for all prior taxable years, over (2) the sum of— (A) the aggregate credits allowed under sections 25F and 36C with respect to the taxpayer for all prior taxable years, and (B) the aggregate