requirements (A) In general The amendments made by subsection (c) shall apply to calendar years beginning after the date of the enactment of this Act. (B) Transition rule In the case of the calendar year which includes the date of the enactment of this Act, section 6039C of the Internal Revenue Code of 1986 shall be applied by only taking into account interests held during the portion of such calendar year which precedes the date of the enactment of this Act.