interests If at any time during a taxable year a taxpayer holds directly or indirectly more than 1 applicable partnership interest in a single partnership, such interests shall be treated as 1 applicable partnership interest for purposes of applying this subsection. (d) Related person For purposes of this section, a person shall be treated as related to another person if the relationship between such persons would be described in section 267(b) or 707(b). (e) Reporting A partnership shall report to the Secretary, and include with the information required to be furnished under section 6031(b) to each partner, the amount of the partner’s deemed compensation amount for the taxable year, if any. A similar rule applies to any entity that receives a report of a deemed compensation amount for the taxable year. (f) Regulations The Secretary shall issue such regulations or other guidance as necessary to carry out this section, including regulations— (1) to prevent the abuse of the purposes of this section, including through— (A) the allocation of income to tax indifferent parties, or (B) a reduction or increase in the invested capital of any partner (including attempts to undervalue or overvalue property), (2) which provide for the application of the rules of subsection (c) to applicable financial instruments and contracts and to entities other than partnerships, (3) which provide that partnership interests shall not fail to be treated as transferred or held in connection with the performance of services merely because the taxpayer also made contributions to the partnership, (4) which provide in appropriate circumstances for purposes of this section the aggregation of assets held by related partnerships or for the disaggregation of assets within 1 partnership, (5) which provide for the application of this section in cases of tiered structures or entities, (6) which provide guidance with respect to forgiveness of any loan described in subsection (b)(4)(B), and (7) which provide rules for transfers or liquidations of