value of all tradable and nontradable covered assets held by the taxpayer as of the close of any taxable year for purposes of section 495(a)(3). (B) Private placement life insurance and annuity contracts For purposes of subparagraph (A)— (i) In general The applicable value of a private placement life insurance or annuity contract (as defined in section 72(e)(12)(D)) as of any date shall be its cash surrender value (as determined under section 7702(f)(2)(A)) on such date. (ii) Adjustments The Secretary shall by regulation provide for adjustments to the cash surrender value determined under clause (i) with respect to any contract to the extent necessary to prevent the avoidance of the purposes of this part, including regulations which ensure that such value as of any time properly reflects the value of any underlying investments with respect to such contract as of such time. (3) Investments in qualified opportunity funds Notwithstanding subsection (b), any investment in a qualified opportunity fund (as defined in section 1400Z–2(d)) shall be treated as a nontradable covered asset. (d) Applicable value For purposes of this part— (1) Tradable covered assets The applicable value of any tradable covered asset as of any date shall be its fair market value on such date. (2) Nontradable covered assets The applicable value of any nontradable covered asset as of any date shall be the greatest of— (A) the original cost basis of such asset, (B) the adjusted basis of such asset, (C) the value determined as of the date of the last event with respect to the asset which establishes such value, (D) in the case of an asset the value of which is included in an applicable financial statement, the value in the latest available statement, (E) the value of such asset determined for purposes of using such asset to secure any indebtedness, and (F) the value of such asset determined under such other valuation method as the Secretary may prescribe. If a covered asset would, but for subsection (c)(3) or any other provision of this part, be