; coordination with title (a) Applicable transfer For purposes of this part— (1) In general The term applicable transfer means— (A) any sale, exchange, disposition, or other transfer if— (i) gain or loss (if any) is, without regard to this part, recognized under this chapter on such sale, exchange, disposition, or other transfer, and (ii) such sale, exchange, disposition, or other transfer is not in the ordinary course of a trade or business, and (B) any disregarded nonrecognition event. (2) Disregarded nonrecognition event The term disregarded nonrecognition event means— (A) any exchange to which section 351 applies, (B) any exchange to which section 1031 applies, (C) any transfer of an asset which— (i) is identified by the Secretary, (ii) involves a C corporation, and (iii) is in connection with an asset with respect to which no gain or loss has been recognized by such corporation, or (D) any other transaction in which gain or loss is not otherwise recognized and which the Secretary determines is necessary to be treated as a disregarded nonrecognition event in order to prevent the avoidance of the purposes of this part. (3) Conversion of assets (A) Nontradable to tradable If a taxpayer holds a nontradable covered asset (other than an investment in a qualified opportunity fund (as defined in section 1400Z–2(d))) which, as part of a transaction or series of transactions, is converted to, or exchanged for, a tradable covered asset, such conversion or exchange shall be treated as a disregarded nonrecognition event if gain or loss (if any) on such conversion or exchange is, without regard to this part, not recognized under this chapter. (B) Tradable to nontradable If a taxpayer holds a tradable covered asset which, as part of a transaction or series of transactions, is converted to, or exchanged for, a nontradable covered asset, such conversion or exchange shall be treated as a taxable event with respect to the asset being converted or exchanged if gain or loss (if any) on such conversion or exchange is, without