(a) with respect to the transfer of such interest). (2) Related person For purposes of this paragraph, a person is related to the taxpayer if— (A) the person is a member of the taxpayer’s family within the meaning of section 318(a)(1), or (B) the person performed a service within the current calendar year or the preceding three calendar years in any applicable trade or business in which or for which the taxpayer performed a service. (f) Reporting by entity of taxpayer’s annual recharacterization amount A partnership shall report to the Secretary, and include with the information required to be furnished under section 6031(b) to each partner, the amount of the partner’s annual recharacterization amount for the taxable year, if any. A similar rule applies to any entity that receives a report of an annual recharacterization amount for the taxable year. (g) Regulations The Secretary shall issue such regulations or other guidance as necessary to carry out this section, including regulations— (1) to prevent the abuse of the purposes of this section, including through— (A) the allocation of income to tax indifferent parties, or (B) a reduction in the invested capital of the partnership (including attempts to undervalue contributed or loaned property), (2) which provide that partnership interests shall not fail to be treated as transferred or held in connection with the performance of services merely because the taxpayer also made contributions to the partnership, (3) which provide for the application of this section in cases where the taxpayer has more than 1 applicable interest in a partnership, and (4) which provide for the application of this section in cases of tiered structures of entities. . (b) Coordination with section 83 Subsection (e) of section 83 is amended by striking or at the end of paragraph (4), by striking the period at the end of paragraph (5) and inserting , or , and by adding at the end the following new paragraph: (6) a transfer of a partnership interest to which section 1061 applies. . (c)