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(F) a transfer by a parent company to a wholly owned subsidiary; or (G) the transfer or sale to or by one person to another person where both persons were initial owners of the registration when the registration was issued; or (2) the cannabis cultivation center registration, medical cannabis dispensary registration, or the controlling interest in a registrant's property is transferred in a transaction to lineal descendants in which no gain or loss is recognized or as a result of a transaction in accordance with Section 351 of the Internal Revenue Code in which no gain or loss is recognized. (p) Pass-through entity tax. (1) For taxable years ending on or after December 31, 2021, a partnership (other than a publicly traded partnership under Section 7704 of the Internal Revenue Code) or Subchapter S corporation may elect to apply the provisions of this subsection. A separate election shall be made for each taxable year. Such election shall be made at such time, and in such form and manner as prescribed by the Department, and, once made, is irrevocable. (2) Entity-level tax. A partnership or Subchapter S corporation electing to apply the provisions of this subsection shall be subject to a tax for the privilege of earning or receiving income in this State in an amount SB3019 Enrolled LRB104 20255 HLH 33706 b Public Act 104-0468