net income derived from prohibited transactions
(i)the term “net income derived from prohibited transactions” means the excess of the gain (including any foreign currency gain, as defined in) from prohibited transactions over the deductions (including any foreign currency loss, as defined in section 988(b)(2)) allowed by this chapter which are directly connected with prohibited transactions; (ii)in determining the amount of the net income derived from prohibited transactions, there shall not be taken into account any item attributable to any prohibited transaction for which there was a loss; and