taxpayers Sec. 495. Applicable taxpayer defined. Sec. 496. Special rules for taxpayers entering or changing status as applicable taxpayers. 495. Applicable taxpayer defined (a) In general For purposes of this part— (1) In general The term applicable taxpayer means, with respect to any taxable year, any taxpayer— (A) which is an individual who met either the income test of paragraph (2) or the asset test of paragraph (3) for each of the 3 immediately preceding taxable years (including taxable years beginning before the date of the enactment of this part which are included in any such 3-taxable year period), or (B) which is— (i) an applicable trust, or (ii) the estate of an individual who was an applicable taxpayer for any taxable year during the 4-taxable year period ending with the taxable year in which the individual died. (2) Income test The requirements of this paragraph are met for any taxable year if the applicable adjusted gross income of the taxpayer for the taxable year exceeds $100,000,000 ($50,000,000 in the case of a married individual filing separately). (3) Asset test The requirements of this paragraph are met for any taxable year if the aggregate applicable value of all tradable and nontradable covered assets held by the taxpayer as of the close of the taxable year exceeds $1,000,000,000 ($500,000,000 in the case of a married individual filing separately). (4) Special rules relating to applicable taxpayer status (A) Termination of status of individual taxpayers A taxpayer who is treated as an applicable taxpayer under paragraph (1)(A) for any taxable year shall continue to be so treated until the first taxable year with respect to which— (i) the taxpayer does not, for each of the 3 taxable years immediately preceding such taxable year, meet either— (I) the income test of paragraph (2) in effect for such preceding taxable year, or (II) the asset test of paragraph (3) in effect for such preceding taxable year, except that each such paragraph shall be applied for purposes of this clause by