(a) section 999.1 applies to the trust as ifi. it ceased at the particular time to be exempt from tax under this Part on its taxable income, and
ii. paragraph e of that section included a reference to the provisions of this Title; and
(b) each person who holds at the particular time an eligible unit in the trust is deemed toi. dispose of, at the time that is immediately before the time that is immediately before the particular time, each of the eligible units for proceeds equal to the cost amount of the unit to the person, and
ii. reacquire the eligible unit at the time that is immediately before the particular time at a cost equal to the fair market value of the unit at the time that is immediately before the particular time.