(2) Special rules relating to tax imposed by reason of paragraph (3) or (4) of subsection (a)
(A) Prohibited allocations The amount involved with respect to any tax imposed by reason of subsection (a)(3) is the amount allocated to the account of any person in violation of section
409 (p)(1).
(B) Synthetic equity
The amount involved with respect to any tax imposed by reason of subsection (a)(4) is the value of the shares on which the synthetic equity is based.
(C) Special rule during first nonallocation year
For purposes of subparagraph (A), the amount involved for the first nonallocation year of any employee stock ownership plan shall be determined by taking into account the total value of all the deemed-owned shares of all disqualified persons with respect to such plan.
(D) Statute of limitations The statutory period for the assessment of any tax imposed by this section by reason of paragraph (3) or (4) of subsection (a) shall not expire before the date which is 3 years from the later of
(i) the allocation or ownership referred to in such paragraph giving rise to such tax, or
(ii) the date on which the Secretary is notified of such allocation or ownership.