year shall be increased as provided in section 492 with respect to any gain from any such transfer, (3) gain or loss with respect to any applicable entity held by the taxpayer shall be taken into account as provided in section 493, and (4) in the case of any gift, bequest, or transfer in trust by an applicable taxpayer or applicable entity held by an applicable taxpayer, section 494 shall apply. 491. Treatment of tradable covered assets (a) In general For purposes of this title, in the case of a taxable event with respect to any tradable covered asset of an applicable taxpayer— (1) notwithstanding any other provision of this title— (A) gain or loss shall be recognized and taken into account in the taxable year in which the taxable event occurs as if the taxpayer had sold the tradable covered asset for its fair market value— (i) in the case of a taxable event described in subsection (b)(1), on the date of the taxable event, and (ii) in the case of a taxable event described in subsection (b)(2), immediately before the taxable event, and (B) except as provided in subsection (c)(1), gain or loss taken into account by reason of a taxable event described in subsection (b)(1) with respect to a tradable covered asset which is a capital asset shall be treated as long-term capital gain or long-term capital loss, respectively, and (2) proper adjustments shall be made in the amount of gain or loss subsequently realized for gain or loss taken into account under paragraph (1). (b) Taxable event For purposes of this part, the term taxable event means, with respect to any tradable covered asset— (1) the holding of such asset as of the close of any taxable year with respect to which a taxpayer is an applicable taxpayer, and (2) any disregarded nonrecognition event. (c) Special rules (1) Characterization as ordinary income or loss Except as provided by the Secretary, subsection (a)(1)(B) shall not apply to any gain or loss from a tradable covered asset if, under any other provision of this title, such gain or loss— (A) is treated