necessary to prevent the avoidance of the purposes of this section, including through— (1) the use of unrelated persons, conduit transactions, or other intermediaries, or (2) transactions or arrangements designed, in whole or in part— (A) to characterize payments otherwise subject to this section as payments not subject to this section, or (B) to substitute payments not subject to this section for payments otherwise subject to this section. . (b) Reporting requirements and penalties (1) In general Subsection (b) of section 6038A is amended to read as follows: (b) Required information (1) In general For purposes of subsection (a), the information described in this subsection is such information as the Secretary prescribes by regulations relating to— (A) the name, principal place of business, nature of business, and country or countries in which organized or resident, of each person which— (i) is a related party to the reporting corporation, and (ii) had any transaction with the reporting corporation during its taxable year, (B) the manner in which the reporting corporation is related to each person referred to in subparagraph (A), and (C) transactions between the reporting corporation and each foreign person which is a related party to the reporting corporation. (2) Additional information regarding base erosion payments For purposes of subsection (a) and section 6038C, if the reporting corporation or the foreign corporation to whom section 6038C applies is an applicable taxpayer, the information described in this subsection shall include— (A) such information as the Secretary determines necessary to determine the base erosion minimum tax amount, base erosion payments, and base erosion tax benefits of the taxpayer for purposes of section 59A for the taxable year, and (B) such other information as the Secretary determines necessary to carry out such section. For purposes of this paragraph, any term used in this paragraph which is also used in section 59A shall have the same meaning as when used in such section. .