; regulations The Secretary shall— (1) provide guidance regarding such information reporting concerning covered transactions as the Secretary deems appropriate, and (2) prescribe such regulations as are necessary or appropriate to prevent avoidance of the purposes of this section, including the use of non-United States persons in such transactions. . (b) Clerical amendment The table of subchapters for chapter 36 of the Internal Revenue Code of 1986 is amended by inserting after the item relating to subchapter B the following new item: Subchapter C. Tax on trading transactions . (c) Effective date The amendments made by this section shall apply to transactions made after December 31, 2017.