Cooper wishes to transfer an investment to his wife, Chloe. However, Chloe does not have sufficient cash to purchase the investment for fair value. Cooper would like to loan the funds to Chloe to facilitate the purchase, as he wants the income on this investment to be reported by her. Chloe will pay interest on the loan, as Cooper expects the investment to generate substantial income.

Which one of the following is not a requirement to ensure that the income on this investment will be taxable to Chloe, and not attributed to Cooper, in the future

A. Interest charges must be at least equal to the greater of the prescribed rate and a commercial rate. B. Chloe must pay Cooper an amount equal to the fair market value of the investment. C. Interest on the loan must be paid from Chloe to Cooper annually, by January 30 of the following year. D. Cooper must elect out of the interspousal rollover