Nonqualified financial property’’ is defined in §1397C(e) as: debt, stock, partnership interests, options, futures contracts, forward contracts, warrants, notional principal contracts, annuities and other similar property.
This would include bank accounts, checking accounts, and other time and demand deposits. Although not specifically listed in the statute, it would seem that cash should also be treated as nonqualified financial property. Nonqualified financial property does not include reasonable amounts of working capital held in cash or cash items or in debt instruments with a term of 18 months or less, or debt instruments described in §1221(a)(4)
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