of determination The delta with respect to any position in applicable property with respect to another position in applicable property (or any combination of such positions) shall be determined— (i) in a commercially reasonable manner, and (ii) except as provided by the Secretary, in a manner which is consistent with the manner used by the taxpayer or the taxpayer's broker for purposes of an applicable financial statement. (C) Timing of delta determination and other special rules Rules similar to the rules of paragraphs (3) and (4) of section 492(d) shall apply for purposes of this paragraph. (4) Applicable property and position defined (A) Applicable property The term applicable property means any item which is— (i) described in paragraph (1), (2), (3), (5), (6), (7), or (8) of section 493(a) (or any item substantially the same as any such item), and (ii) of a type which is actively traded. (B) Position (i) In general The term position means an interest in applicable property. (ii) Derivatives excluded Such term shall not include a derivative (as defined in section 493). (5) Positions held by related persons, etc (A) In general In determining whether 2 or more positions are offsetting, the taxpayer shall be treated as holding any position held by a related party (within the meaning of section 492(f)). (B) Certain flowthrough entities If part or all of the gain or loss with respect to a position held by a partnership, trust, or other entity would properly be taken into account for purposes of this chapter by a taxpayer, then, except to the extent otherwise provided in regulations, such position shall be treated as held by the taxpayer. (6) Special rules for foreign currency (A) Position to include interest in certain debt For purposes of paragraph (4)(B)(i), an obligor's interest in a nonfunctional currency denominated debt obligation is treated as a position in the nonfunctional currency. (B) Actively traded requirement For purposes of paragraph (4)(A)(ii), foreign currency for which there is an active