Allocation of basis difference
For purposes of subparagraph (A)(i)—
(i) In general
(i)In general#
The basis difference with respect to any relevant foreign asset shall be allocated to taxable years using the applicable cost recovery method under this chapter.
(ii)Special rule for disposition of assets#
Except as otherwise provided by the Secretary, in the case of the disposition of any relevant foreign asset—
(I) the basis difference allocated to the taxable year which includes the date of such disposition shall be the excess of the basis difference with respect to such asset over the aggregate basis difference with respect to such asset which has been allocated under clause (i) to all prior taxable years, and
(II) no basis difference with respect to such asset shall be allocated under clause (i) to any taxable year thereafter.
(ii)(I)#
the basis difference allocated to the taxable year which includes the date of such disposition shall be the excess of the basis difference with respect to such asset over the aggregate basis difference with respect to such asset which has been allocated under clause (i) to all prior taxable years, and
(ii)(II)#
no basis difference with respect to such asset shall be allocated under clause (i) to any taxable year thereafter.