such time and in such manner as the Secretary may provide and, once made with respect to any asset, may be revoked only with the consent of the Secretary (and subject to such requirements as the Secretary may provide to ensure proper taxation of gains and losses with respect to such assets). If the Secretary determines that it is consistent with the purposes of this section, the Secretary may permit an illiquid taxpayer to elect to apply this paragraph (and subsection (f)) with respect to such portion of non-readily tradable assets of the taxpayer as the Secretary determines is consistent with such purposes. (f) Special limited deferral option accounts (1) In general The Secretary shall issue regulations or other guidance under which, in the case of any taxpayer subject to the requirements of this subsection (including by reason of subsection (e)(2)(B)(iv) or (e)(4) or paragraph (2)(K) of this subsection), the taxpayer’s tax liability under this section, and the timing of any such liability, with respect to any non-readily tradable assets held by such taxpayer are determined on the basis of the Special Limited Deferral Option account rules prescribed by the Secretary under this subsection. (2) Special Limited Deferral Option Account rules The Special Limited Deferral Option account rules prescribed by the Secretary under this subsection shall, except as otherwise provided by the Secretary, be consistent with the following: (A) Any taxpayer subject to this subsection shall be treated as having an Special Limited Deferral Option account (hereafter in this subsection referred to as an SLDO account ) which consists of the non-readily tradable assets held by such taxpayer (or, as the case may be, to the portion of such assets described in subsection (e)(2)(B)(iv) or (e)(4)(C)) (hereafter in this subsection referred to as the SLDO assets ). (B) Except as provided in subparagraph (K)— (i) in the case of the first year in which a taxpayer becomes subject to this subsection and so has assets in the SLDO account, the