Basis difference
(i) In general
(i)In general#
The term “basis difference” means, with respect to any relevant foreign asset, the excess of—
(I) the adjusted basis of such asset immediately after the covered asset acquisition, over
(II) the adjusted basis of such asset immediately before the covered asset acquisition.
(i)(I)#
the adjusted basis of such asset immediately after the covered asset acquisition, over
(i)(II)#
the adjusted basis of such asset immediately before the covered asset acquisition.
(ii)Built-in loss assets#
In the case of a relevant foreign asset with respect to which the amount described in clause (i)(II) exceeds the amount described in clause (i)(I), such excess shall be taken into account under this subsection as a basis difference of a negative amount.
(iii)Special rule for section 338 elections#
In the case of a covered asset acquisition described in paragraph (2)(A), the covered asset acquisition shall be treated for purposes of this subparagraph as occurring at the close of the acquisition date (as defined in section 338(h)(2)).