delegate) may prescribe) not to have this section apply. (3) Certain terms Any term used in this section which is also used in chapter 21 of such Code shall have the same meaning as when used in such chapter. (e) Regulations The Secretary of the Treasury (or the Secretary’s delegate) shall prescribe such regulations or other guidance as may be necessary to carry out the purposes of this section, including— (1) regulations or other guidance to prevent the avoidance of the purposes of the limitations under this section