such adjusted bases. Such rules shall also provide proper adjustments to adjusted bases where ownership is held through tiered entities. (B) Other applicable entities Rules similar to the rules of clause (i) shall apply to applicable entities other than partnerships. (C) No deductions or credits for basis increases If there is any increase in the applicable entity's adjusted basis of any asset by reason of subparagraph (A), no deduction or credit shall be allowed under this title with respect to the portion of such adjusted basis attributable to such increase. (3) Definitions Any term used in this subsection which is also used in section 493 shall have the same meaning as when used in such section. (d) Special election for certain tradable assets of applicable taxpayers (1) In general If a qualified taxpayer makes an election under this subsection, then any stock held by such qualified taxpayer which would (but for such election) be a tradable covered asset and which is specified in such election shall be treated as a nontradable capital asset of the taxpayer for purposes of this part. (2) Limitations (A) Only stock of a single entity taken into account An election made under this subsection may not specify stock in more than one C corporation or specify more than one class of stock in such corporation. (B) Value (i) In general The aggregate value of stock specified in an election made under this subsection shall not exceed $1,000,000,000. (ii) Determination For purposes of clause (i), the value of any stock specified in an election made under this section shall be determined as of the last day of the first taxable year for which the taxpayer is an applicable taxpayer. (3) Qualified taxpayer For purposes of this subsection, the term qualified taxpayer means any taxpayer— (A) which is not an estate or trust, and (B) for which the first taxable year for which such taxpayer is an applicable taxpayer is a taxable year that begins before January 1, 2025. (4) Election (A) In general Any election under this subsection