of gain or loss subsequently realized for gain or loss taken into account under subparagraph (A), and (2) if there is gain from the applicable transfer, the tax imposed by this chapter for the taxable year (determined without regard to this section) shall be increased by the sum of the deferral recapture amounts determined under subsection (b) for each such transfer. (b) Deferral recapture amount (1) In general For purposes of this part— (A) In general The term deferral recapture amount means, with respect to any applicable transfer of any nontradable covered asset, the aggregate amount of interest (determined in the manner provided under paragraph (3)) on the deemed tax amount determined under paragraph (2) for each taxable year to which gain is allocated under paragraph (2)(A) and which precedes the taxable year of the applicable transfer. (B) Limitation on amount The amount determined under subparagraph (A) with respect to any applicable transfer shall not exceed the applicable percentage of the gain from such transfer. For purposes of this subparagraph, the applicable percentage is the excess of— (i) 49 percent, over (ii) in the case of the transfer of a nontradable covered asset which— (I) is a capital asset, the rate of tax in effect under section 1(h)(1)(D) for the taxable year of the transfer, or (II) is not a capital asset, the highest rate of tax in effect under section 1 for such taxable year. (2) Deemed tax amount For purposes of paragraph (1)— (A) In general The deemed tax amount for any taxable year preceding the taxable year of any applicable transfer of a nontradable covered asset shall be the amount determined— (i) first, except as provided in subparagraph (B), by allocating the amount of gain from such transfer ratably to each day in the taxpayer's holding period of such asset, and (ii) then by multiplying the amount allocated under clause (i) to days in such preceding taxable year by— (I) if such asset is a capital asset, the rate of tax in effect under section 1(h)(1)(D) for the taxable year