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 apply to any transfer of property by two or more persons which are corporations if the combined average annual gross receipts of such persons for the 3-taxable year period which precedes the taxable year of the transfer exceeds $500,000,000. (2) Exception Clause (i) shall not apply if— (A) such persons control the corporation to which the property is transferred immediately before the transfer, (B) another corporation controls all such persons and the corporation to which the property is transferred immediately before the transfer, or (C) all such persons meet the gross receipts test of section 448(c)(1) for the taxable year in which the transfer is made. (3) Aggregation and other special rules Rules similar to the rules of paragraphs (2) and (3) of section 448(c) shall apply for purposes of paragraph (1). (4) Inflation adjustment In the case of any taxable year beginning after 2024, the dollar amount in paragraph (1) shall be increased by an amount equal to— (A) such dollar amount, multiplied by (B) 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. (5) 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— (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