part— (1) Applicable entity The term applicable entity means any— (A) partnership, (B) S corporation, or (C) other pass-through entity specified in regulations or guidance prescribed by the Secretary. (2) Election to treat entity as applicable taxpayer for taxable events involving tradable assets If an applicable entity elects the application of this paragraph for any taxable year— (A) this section shall not apply with respect to any gain or loss in connection with a taxable event involving any tradable covered asset held directly (or indirectly through 1 or more nontradable interests) by such entity, and (B) such entity shall be treated as an applicable taxpayer for purposes of applying sections 490(1) and 491 to such taxable event. Such an election shall be made at such time and in such manner as the Secretary may prescribe and, once made, shall be irrevocable without the consent of the Secretary. (e) Nontradable interest For purposes of this part, the term nontradable interest means any ownership interest in an applicable entity which is a nontradable covered asset. (f) Regulations and guidance The Secretary shall prescribe such regulations and guidance as are necessary to carry out the provisions of this section, including regulations or guidance necessary— (1) to prevent the use of pass-through entities to avoid the purposes of this part, and (2) to simplify the application of this part. 494. Treatment of gifts, bequests, and transfers in trust (a) In general (1) Deemed sale If any person described in paragraph (3) transfers any covered asset by gift, upon death, or in trust, such covered asset shall be treated as sold by such person for its fair market value to the transferee on the date of such gift, death, or transfer. (2) No recognition for losses on transfers by gift or in trust (A) In general No loss shall be recognized with respect to any covered asset which is treated as sold under subsection (a) by reason of a transfer by gift or in trust. (B) Amount of gain for transferee If a loss is not