Identification requirements.

Identification requirements. In order to qualify for this election
(i) The marketable securities must be identified on the books and records of the U.S. trade or business within 30 days of the date an equivalent amount of U.S. assets ceases to be U.S. assets; and
(ii) On the date a marketable security is identified, its adjusted basis must not exceed its fair market value.

Source

26 CFR § 1.884-2T


Scoping language

None
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