(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 as gain or loss from the sale or exchange of an asset which is not a capital asset, or (B) is treated as ordinary income or loss on a basis other than the taxpayer’s holding period in such asset. (2) Holding period For purposes of this title, any taxable event described in subsection (b)(1) with respect to any tradable covered asset shall not be taken into account in determining the holding period of the taxpayer with respect to such tradable covered asset. (3) Proper adjustments for subsequent gain or loss For purposes of subsection (a)(2), section 492(a)(1)(B), section 493(c)(1)(A)(ii), and section 493(c)(3)(C), the proper adjustments required under such provisions shall include such adjustments in basis of property, or such other adjustments in respect of property, as the Secretary determines necessary or appropriate. 492. Deferral recapture amount on applicable transfers of nontradable covered assets (a) In general If there is an applicable transfer during a taxable year of a nontradable covered asset of an applicable taxpayer— (1) in the case of an applicable transfer which is a disregarded nonrecognition event— (A) notwithstanding any other provision of this title, gain or loss shall be recognized and taken into account by the taxpayer (including for purposes of paragraph (2) and subsection (c)) in the taxable year in which the transfer occurs as if the taxpayer had sold the nontradable covered asset for its fair market value immediately before such transfer, and (B) proper adjustments shall be made in the amount 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)