net underlying long-term capital gain
Defined in 1 place of the United States Code.
For purposes of this section, in the case of any constructive ownership transaction with respect to any financial asset, the term "net underlying long-term capital gain" means the aggregate net capital gain that the taxpayer would have had if—
Source
- 1999–present26 U.S.C. § 1260Internal Revenue Code · Gains from constructive ownership transactions · for purposes of this section
For purposes of this section, in the case of any constructive ownership transaction with respect to any financial asset, the term “net underlying long-term capital gain” means the aggregate net capital gain that the taxpayer would have had if—
(1) the financial asset had been acquired for fair market value on the date such transaction was opened and sold for fair market value on the date such transaction was closed, and
(2) only gains and losses that would have resulted from the deemed ownership under paragraph (1) were taken into account.
Source
- 201326 U.S.C. § 1260Internal Revenue Code · Gains from constructive ownership transactions · for purposes of this section