those assets to support their lavish lifestyles, all completely tax-free, and (2) under the provisions of title II of this Act, closing loopholes in the tax code that allow high income and high net worth taxpayers to shield their income from taxation, including the loophole that allows ultra wealthy taxpayers to transfer untaxed appreciated assets to their heirs at death and such heirs to sell such assets completely tax-free. I Elimination of deferral for applicable taxpayers 101. Elimination of deferral of tax (a) In general Subchapter E of chapter 1 is amended by adding at the end the following new part: IV Elimination of deferral for applicable taxpayers Subpart A. General provisions. Subpart B. Definitions and rules relating to applicable taxpayers. Subpart C. Other definitions and rules. A General provisions Sec. 490. Elimination of deferral of tax for applicable taxpayers. Sec. 491. Treatment of tradable covered assets. Sec. 492. Deferral recapture amount on applicable transfers of nontradable covered assets. Sec. 493. Special rules for application of nondeferral rules to certain pass-through entities. Sec. 494. Treatment of gifts, bequests, and transfers in trust. 490. Elimination of deferral of tax for applicable taxpayers In the case of an applicable taxpayer for any taxable year— (1) if there is a taxable event with respect to any tradable covered asset of the taxpayer during the taxable year, gain or loss shall be recognized as provided in section 491, (2) if there is an applicable transfer by the taxpayer during the taxable year of any nontradable covered asset— (A) if such applicable transfer is a disregarded nonrecognition event, gain or loss shall be recognized as provided in section 492(a)(1), and (B) the tax imposed by this chapter for the taxable year shall be increased as provided in section 492 with respect to any gain from any such transfer, (3) gain or loss with respect to any applicable entity held by the taxpayer shall be taken into account as provided in section 493, and (4) in the case