Does the assignee and assignor have to be unitary for the entire year of assignment?
No. The assignee and assignor need to be part of the combined reporting group on the last day of the year in which the credit was first allowed and the last day of the year in which the credit is assigned for credits first allowed in taxable years beginning on or after July 1, 2008. The assignee and assignor need to be part of the combined reporting group on June 30, 2008, and the last day of the year in which the credit is assigned for credits first allowed in taxable years before July 1, 2008.
