Hans Myers Wishes to Transfer an Investment to His Wife

Hans Myers wishes to transfer an investment to his wife, Olga. However, Olga does not have sufficient cash to purchase the investment for fair value. Hans would like to loan the funds to Olga to facilitate the purchase, as he wants the income on this investment to be reported by her. Olga will pay interest on the loan, as Hans 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 Olga, and not attributed to Hans, in the future?

A) Hans must elect to realize any gains inherent in the property at the transfer date.
B) Interest on the loan must be paid from Olga to Hans annually, by January 30 of the following year.
C) Olga must pay no less than the full fair market value of the investment (although this can include the loan's face value) .
D) The interest rate on the loan must be at fair market value, even when that rate is greater than the prescribed rate.