Unrealized API Gains and Losses

Unrealized API Gains and Losses means, with respect to a Passthrough Entity's assets, all unrealized capital gains and losses that would be:
(i) Realized if those assets were disposed of for fair market value in a taxable transaction on the relevant date; and
(ii) Allocated to an API Holder with respect to its API, taking into account the principles of section 704(c).


26 CFR § 1.1061-1

Scoping language

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