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(I needed to learn about this because I'm in possibly the same situation as you: during enrollment before the beginning of the year I projected I would be eligible, and requested APTC accordingly, but I ended up ineligible due to cap gains and will have to pay it back. Although since my prior year liability was zero, I can delay payment until April without penalty, FWIW.)

(I needed to learn about this because I'm in possibly the same situation as you: during enrollment before the beginning of the year I projected I would be eligible, and requested APTC accordingly, but I ended up ineligible due to cap gains and will have to pay it back. Although since my prior year liability was zero, I can delay payment until April without penalty, FWIW.) (update: due to COVID the repayment was further delayed until July. Not that it makes much difference.)

TLDR: LTCG are counted, but neither side of the comparison is quite as you described

7> If your total income is below a certain limit, long-term capital gains are taxed with 0% (again, up to a certain limit).

If your total income is below a certain limit, long-term capital gains are taxed with 0% (again, up to a certain limit).