subsection (f) asset

The term “subsection (f) asset” means any property which, as of the date of any sale of stock referred to in paragraph (1), is not a capital asset and is property owned by, or subject to an option to acquire held by, the consenting corporation. For purposes of this subparagraph, land or any interest in real property (other than a security interest), and unrealized receivables or fees (as defined in subsection (b)(4)), shall be treated as property which is not a capital asset.

If manufacture, construction, or production with respect to any property described in subparagraph (A) has commenced before any date of sale described therein, the term “subsection (f) asset” includes the property resulting from such manufacture, construction, or production.

In the case of land or any interest in real property (other than a security interest) described in subparagraph (A), the term “subsection (f) asset” includes any improvements resulting from construction with respect to such property if such construction is commenced (by the consenting corporation or by a transferee corporation which has agreed to the application of paragraph (2)) within 2 years after the date of any sale described in subparagraph (A).