of the first taxable year described in paragraph (1) as a tradable covered asset for purposes of applying section 491(b)(1) and this subsection. (B) Determination of gain (i) In general For purposes of applying section 491(a)(1)(A), the fair market value of any asset with respect to which an election is in effect under subparagraph (A) shall be the amount specified by the taxpayer in such election, except that such value may not, unless otherwise provided by the Secretary, be less than the taxpayer's adjusted basis in such asset as of the end of the first taxable year described in paragraph (1). (ii) No deductions or credits for basis increases If there is any increase under this part in the taxpayer's adjusted basis of any asset by reason of an election under this paragraph, no deduction or credit shall be allowed under this title with respect to the portion of such adjusted basis attributable to such increase. (C) Only significant owner of applicable entity may elect In the case of a nontradable covered asset which is a nontradable interest in an applicable entity, an applicable taxpayer may make an election under subparagraph (A) with respect to such asset only if such taxpayer is a significant owner (as defined in section 493(b)(4)(A)) of such entity with respect to whom a notice is in effect under section 493(b)(2)(A) for the taxable year for which the election is being made. (4) Special rule where delay in reporting by applicable entity (A) In general If— (i) there is a delay in reporting to an applicable taxpayer by 1 or more applicable entities by reason of section 493(c)(4), and (ii) any gain or loss is reported by such entities to such taxpayer under section 493(c)(1)(A)(i) and is taken into account in such taxpayer's taxable year immediately succeeding the first taxable year described in paragraph (1), then, subject to such rules as the Secretary may prescribe, the taxpayer may elect under paragraph (1)(B) to treat the net tax liability described in subparagraph (B) as net first-year tax liability