passive foreign exchange gain
(3) Passive foreign exchange gain For purposes of this subsection, the term “passive foreign exchange gain” means— (A) real estate foreign exchange gain, (B) foreign currency gain (as defined in section 988(b)(1) ) which is not described in subparagraph (A) and which is attributable to— (i) any item of income or gain described in subsection (c)(2), (ii) the acquisition or ownership of obligations (other than foreign currency gain attributable to any item of income or gain described in clause (i)), or (iii) becoming or being the obligor under obligations (other than foreign currency gain attributable to any item of income or gain described in clause (i)), and (C) any other foreign currency gain as determined by the Secretary.