The tracking property rules are anti-avoidance provisions which should be interpreted broadly. Therefore, there need not be a direct mechanism linking the value of a property to a particular tracked property, as long as the two are correlated in some way.
If the particular tracked property is corporate shares, it is necessary to determine whether the taxpayer would have a significant interest in the corporation if it held the shares directly:
[I]t is our view that the taxpayer's percentage interest in the tracking property must be applied to the tracked property to determine the percentage that would be held by the taxpayer.
[A] property does not have to meet the requirements of the definition of tracking property at the time of its disposition in order to be a mark-to-market property for the year as long as it was a tracking property and a fair value property at some point in the year, and not an excluded property at any time in the year.
Under the above interpretations, a warrant is generally considered tracking property.