to prevent the abuse of the purposes of, this subparagraph, including rules— (A) to prevent the avoidance of the application of this subsection through the use of a series of transactions designed and executed as parts of a unitary plan, and (B) for the nonapplication of the rules of paragraph (1) where such nonapplication is consistent with the purposes of this subsection. . (c) Effective date The amendments made by this section shall apply to transfers after the date of the enactment of this Act.