Unreversed inclusions
(3) Unreversed inclusions(i) General rule. The term unreversed inclusions means with respect to any section 1296 stock, the excess, if any, of (A) The amount of mark to market gain included in gross income of the United States person under paragraph (c)(1) of this section with respect to such stock for prior taxable years; over (B) The amount allowed as a deduction to the United States person under paragraph (c)(3) of this section with respect to such stock for prior taxable years. (ii) Section 1291 adjustment. The amount referred to in paragraph (a)(3)(i)(A) of this section shall include any amount subject to section 1291 under the coordination rule of paragraph (i)(2)(ii) of this section. (iii) Example. An example of the computation of unreversed inclusions is as follows: