unrecognized gain

(A)The term “unrecognized gain” means— (i)in the case of any position held by the taxpayer as of the close of the taxable year, the amount of gain which would be taken into account with respect to such position if such position were sold on the last business day of such taxable year at its fair market value, and (ii)in the case of any position with respect to which, as of the close of the taxable year, gain has been realized but not recognized, the amount of gain so realized. (B)For purposes of paragraph (2)(A)(ii), the unrecognized gain with respect to any offsetting position shall be the excess of the fair market value of the position at the time of the determination over the fair market value of the position at the time the taxpayer identified the position as a position in an identified straddle. (C) (i)Each taxpayer shall disclose to the Secretary, at such time and in such manner and form as the Secretary may prescribe by regulations— (I)each position (whether or not part of a straddle) with respect to which, as of the close of the taxable year, there is unrecognized gain, and (II)the amount of such unrecognized gain. (ii)Clause (i) shall not apply— (I)to any position which is part of an identified straddle, (II)to any position which, with respect to the taxpayer, is property described in paragraph (1) or (2) ofor to any position which is part of a hedging transaction (as defined in section 1256(e)), or (III)with respect to any taxable year if no loss on a position (including a regulated futures contract) has been sustained during such taxable year or if the only loss sustained on such position is a loss described in subclause (II). (b)

Source

26 USC § 1092(a)(3)(A)


Scoping language

None: Default is title Scope
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