net unrealized built-in gain
Defined in 2 places of the United States Code.
The term “net unrealized built-in gain” means the amount (if any) by which—
(A) the fair market value of the assets of the S corporation as of the beginning of its 1st taxable year for which an election under section 1362(a) is in effect, exceeds
(B) the aggregate adjusted bases of such assets at such time.
Source
- 1994–present26 U.S.C. § 1374Internal Revenue Code · Tax imposed on certain built-in gains · for purposes of this section
The terms “net unrealized built-in gain” and “net unrealized built-in loss” mean, with respect to any old loss corporation, the amount by which—
(I) the fair market value of the assets of such corporation immediately before an ownership change is more or less, respectively, than
(II) the aggregate adjusted basis of such assets at such time.
Source
- 1994–present26 U.S.C. § 382Internal Revenue Code · Limitation on net operating loss carryforwards and certain built-in losses following ownership change · for purposes of this section