Jack McMillan wishes to transfer an investment to his wife, Hilda. However, Hilda does not have sufficient cash to purchase the investment for fair value. Jack would like to loan the funds to Hilda to facilitate the purchase, as he wants the income on this investment to be reported by her. Hilda will pay interest on the loan, as Jack 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 Hilda, and not attributed to Jack, in the future? Jack must elect to realize any gains inherent in the property at the transfer date. Interest on the loan must be paid from Hilda to Jack annually, by January 30 of the following year. Hilda must pay no less than the full fair market value of the investment (although this can include the loans face value). The interest rate on the loan must be at fair market value, even when that rate is greater than the prescribed rate.