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@Donna1 wrote:

(1) I can allocate using any percentage that I want to. If this is true, then to avoid the repayment, I could allocate 0 to my client.

(2) That does not seem reasonable.

(3) If I do any allocating, what if anything needs to be filed for the daughter.

 

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(1) Yes, *IF* both mom and daughter agree.  If they do not agree, it needs to be split.

(2) Yes, I agree, but that is how they wrote the Regulations.

(3) The daughter needs to file a tax return with Form 8962.   Because of her low income, the software will likely give her even more Premium Tax Credit.  Although it is slightly questionable if that is technically allowed, the IRS  has been accepting that since the Premium Tax Credit started in 2014.