Although the IRS literature does not directly address the issue of whether the substitute payments in lieu of interest or dividends are considered investment income for net investment income tax purposes, it would seem that they would qualify as they are a substitute for interest and dividends that qualify. I'm not sure why they don't automatically populate on the 2021 form 4952, line 4(a), but you can manually enter them if you access the Form 4952 Investment Interest Expense Worksheet (on line 9) which is available in the desktop version of TurboTax.
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