in section 642(c)(5)), subsection (a) shall not apply to the portion of such transfer which is to or for the use of an organization described in section 170(b)(1)(A) (other than in clauses (vii) or (viii)). (3) Qualified disability trusts and cemetery perpetual care funds Subsection (a) shall not apply to transfers to any qualified disability trust (as defined in section 642(b)(2)(C)(ii)) or to transfers to any cemetery perpetual care fund described in section 642(i). (d) Basis of transferee (1) In general Notwithstanding sections 1014 and 1015, to the extent that subsection (a) applies to any transfer of property— (A) except as provided in subparagraph (B), the basis of the property in the hands of the transferee shall be the fair market value of the property (consistent with the amount taken into account by the transferor under subsection (a)), and (B) in the case such transfer is a transfer upon death to any individual described in subsection (c)(1)(A)(i), the basis of the property in the hands of the transferee shall be the same as it would be in the hands of the transferor, except that if such basis (adjusted for the period before the date of the transfer as provided in section 1016) is greater than the fair market value of the property at the time of death, then for the purpose of determining loss the basis shall be such fair market value. (2) Consistent basis rules for transfers by death In the case of any transfer upon death, rules similar to section 1014(f) shall apply for purposes of this section. (e) Application of depreciation recapture rules Paragraphs (1) and (2) of section 1245(b) and paragraphs (1) and (2) of section 1250(d) shall not apply to any property treated as sold by reason of subsection (a). B Definitions and rules relating to applicable taxpayers Sec. 495. Applicable taxpayer defined. Sec. 496. Special rules for taxpayers entering or changing status as applicable taxpayers. 495. Applicable taxpayer defined (a) In general For purposes of this part— (1) In general The term applicable