Taxpayer transferred SFC stock to a domestic corporation in December 2017. This incorporation transaction was subject to the anti-avoidance rules in the Sec. 965 proposed regs and had to be disregarded. Taxpayer filed both the individual and corporation returns for 2017 and disregarded the transfer of the stock, thereby complying with the proposed regs. The individual, i.e. the previous stockholder, elected to pay tax in installments. Now the final regulations come out in January 2019, and they provide an exception for incorporation transactions, see 1.965-4(e)(3). The individual would like to get a refund of Sec. 965 tax and the corporation (which is now regarded as a shareholder) would like to pay the 2017 Sec. 965 tax. The problem is there is no late election relief if the corporation wants to pay tax in installments. I appreciate any advice.