net unrealized built-in gain
(1) Net unrealized built-in gain The term “net unrealized built-in gain” means the amount (if any) by which— (A) the fair market value of the assets of the S corporation as of the beginning of its 1st taxable year for which an election under section 1362(a) is in effect, exceeds (B) the aggregate adjusted bases of such assets at such time.
26 USC § 1374(d)(1)
None identified. Default scope is assumed to be the entire title.