late-year ordinary loss
(8) Elective deferral of certain late-year losses (A) In general Except as otherwise provided by the Secretary, a regulated investment company may elect for any taxable year to treat any portion of any qualified late-year loss for such taxable year as arising on the first day of the following taxable year for purposes of this title. (B) Qualified late-year loss For purposes of this paragraph, the term “qualified late-year loss” means— (i) any post-October capital loss, and (ii) any late-year ordinary loss. (C) Post-October capital loss For purposes of this paragraph, the term “post-October capital loss” means— (i) any net capital loss attributable to the portion of the taxable year after October 31, or (ii) if there is no such loss— (I) any net long-term capital loss attributable to such portion of the taxable year, or (II) any net short-term capital loss attributable to such portion of the taxable year. (D) Late-year ordinary loss For purposes of this paragraph, the term “late-year ordinary loss” means the sum of any post-October specified loss and any post-December ordinary loss. (E) Post-October specified loss For purposes of this paragraph, the term “post-October specified loss” means the excess (if any) of— (i) the specified losses (as defined in section 4982(e)(5)(B)(ii)) attributable to the portion of the taxable year after October 31, over (ii) the specified gains (as defined in section 4982(e)(5)(B)(i)) attributable to such portion of the taxable year. (F) Post-December ordinary loss For purposes of this paragraph, the term “post-December ordinary loss” means the excess (if any) of— (i) the ordinary losses not described in subparagraph (E)(i) and attributable to the portion of the taxable year after December 31, over (ii) the ordinary income not described in subparagraph (E)(ii) and attributable to such portion of the taxable year. (G) Special rule for companies determining required capital gain distributions on taxable year basis In the case of a company to which an election under section 4982(e)(4) applies— (i) if such company’s taxable year ends with the month of November, the amount of qualified late-year losses (if any) shall be computed without regard to any income, gain, or loss described in subparagraphs (C) and (E), and (ii) if such company’s taxable year ends with the month of December, subparagraph (A) shall not apply.