to exist, after) the merger, consolidation, acquisition, or transfer (as the case may be), or (III) either the acquiring corporation or the acquired corporation meets the gross receipts test of section 448(c)(1) for the taxable year in which the merger, consolidation, acquisition, or transfer is completed. (iv) Aggregation and other special rules Rules similar to the rules of paragraphs (2) and (3) of section 448(c) shall apply for purposes of clause (i)(II), except that (unless otherwise provided by the Secretary) the rules of section 448(c)(2) shall not apply in determining the average annual gross receipts of the acquired corporation. (v) Inflation adjustment In the case of any taxable year beginning after 2024, the dollar amount in clause (ii)(III) 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) for the calendar year in which such taxable year begins, determined by substituting calendar year 2023 for calendar year 2016 in subparagraph (A)(ii) thereof. If any amount as increased under the preceding sentence is not a multiple of $1,000,000, such amount shall be rounded to the nearest multiple of $1,000,000. (vi) Regulations and guidance The Secretary may prescribe such regulations and other guidance as are necessary or appropriate to carry out, and to prevent the abuse of the purposes of, this subparagraph, including rules— (I) to prevent the avoidance of the application of this subparagraph through the use of a series of transactions designed and executed as parts of a unitary plan, and (II) for the nonapplication of the rules of clause (i) where such nonapplication is consistent with the purposes of this subparagraph. . (b) Transfers to corporations controlled by transferors Section 351 is amended by redesignating subsection (h) as subsection (i) and by inserting after subsection (g) the following new subsection: (h) Special rule with respect to multiple transferors (1) In general Subsection (a) shall not