provided in regulations, such derivative or investment shall be treated as held by the taxpayer. (f) Related party For purposes of this section— (1) In general A person is a related party to the taxpayer if, with respect to any period during which a derivative or underlying investment is held by such person, such person— (A) is the taxpayer’s spouse, (B) is a dependent of the taxpayer or any other taxpayer with respect to whom the taxpayer is a dependent, (C) is an individual, corporation, partnership, trust, or estate which controls, or is controlled by (within the meaning of section 954(d)(3)), the taxpayer or any individual described in subparagraph (A) or (B) with respect to the taxpayer (or any combination thereof), (D) is an individual retirement plan, Archer MSA (as defined in section 220(d)), or health savings account (as defined in section 223(d)), of the taxpayer or of any individual described in subparagraph (A) or (B) with respect to the taxpayer, (E) is an account under a qualified tuition program described in section 529, an ABLE account (as defined in section 529A(f)(6)), or a Coverdell education savings account (as defined in section 530(b)) if the taxpayer, or any individual described in subparagraph (A) or (B) with respect to the taxpayer, is the designated beneficiary of such account or has the right to make any decision with respect to the investment of any amount in such account, (F) is an account under— (i) a plan described in section 401(a), (ii) an annuity plan described in section 403(a), (iii) an annuity contract described in section 403(b), or (iv) an eligible deferred compensation plan described in section 457(b) and maintained by an employer described in section 457(e)(1)(A), if the taxpayer or any individual described in subparagraph (A) or (B) with respect to the taxpayer has the right to make any decision with respect to the investment of any amount in such account, or (G) files a consolidated return (within the meaning of section 1501) with the taxpayer for any taxable year which