to defer recognition of income under section 83(i). . (d) Information reporting Section 6051(a) of the Internal Revenue Code of 1986 is amended by striking and at the end of paragraph (14), by striking the period at the end of paragraph (15) and inserting a comma, and by inserting after paragraph (15) the following new paragraphs: (16) the amount includible in gross income under subparagraph (A) of section 83(i)(1) with respect to an event described in subparagraph (B) of such section which occurs in such calendar year, and (17) the aggregate amount of income which is being deferred pursuant to elections under section 83(i), determined as of the close of the calendar year. . (e) Penalty for failure of employer To provide notice of tax consequences Section 6652 of the Internal Revenue Code of 1986 is amended by adding at the end the following new subsection: (p) Failure To provide notice under section 83(i) In the case of each failure to provide a notice as required by section 83(i)(6), at the time prescribed therefor, unless it is shown that such failure is due to reasonable cause and not to willful neglect, there shall be paid, on notice and demand of the Secretary and in the same manner as tax, by the person failing to provide such notice, an amount equal to $100 for each such failure, but the total amount imposed on such person for all such failures during any calendar year shall not exceed $50,000. . (f) Guidance Not later than December 31, 2018, the Secretary of the Treasury (or the Secretary's delegate) shall issue guidance with respect to section 83(i) of the Internal Revenue Code of 1986 (as added by this section), including guidance relating to— (1) the determination the time stock first becomes transferable under such section