of an investment hedging unit— (A) the termination or transfer of such derivative, and (B) the close of any taxable year if the taxpayer has rights or obligations with respect to such derivative at such time, and (2) with respect to all derivatives and underlying investments which are part of the same investment hedging unit— (A) the establishment of the investment hedging unit, (B) the termination or transfer of any such derivative, (C) the sale or exchange of all or any portion of any such underlying investment, (D) the entering into of another derivative, or the acquisition of an additional amount of such underlying investment, after the establishment of the investment hedging unit if such derivative or additional amount is treated as part of the investment hedging unit under section 492, and (E) in the case of— (i) an investment hedging unit with respect to which an election is in effect under section 492(b), the close of each business day, and (ii) any other investment hedging unit, the close of any taxable year if the applicable hedging period with respect to such unit includes such close. (3) Termination or transfer For purposes of this part, the term termination or transfer includes, with respect to any derivative, any termination or transfer by offsetting, by taking or making delivery, by exercise or being exercised, by assignment or being assigned, by lapse, by sale or other disposition, by assumption, or otherwise. (d) Treatment of payments with respect to certain derivatives Notwithstanding any other provision of this title— (1) In general Except as provided in regulations prescribed by the Secretary, in the case of a payment pursuant to a derivative (other than an option)— (A) any item of income, deduction, gain, or loss with respect to the payment shall be taken into account for purposes of this title at the time of the payment, and (B) proper adjustment shall be made in the amount of any subsequent gain or loss for items taken into account by reason of subparagraph (A). This paragraph shall not