year , and (B) the amount of the tax imposed under such section shall be reduced by an amount which bears the same ratio to such amount (determined without regard to this subsection) as— (i) the number of days in the calendar year after the date of the individual's death, bears to (ii) 365. (2) Coordination with estate tax For purposes of section 2053, the tax imposed by this section for the year of the decedent's death shall be considered to have been imposed before such death. (b) Application to non-Residents In the case of any nonresident alien individual, this subtitle shall apply only to the property of such individual which is situated in the United States (determined under rules similar to the rules under subchapter B of chapter 11). (c) Application to covered expatriates In the case of an individual who is a covered expatriate (as defined in section 877A), section 2901(a) shall be applied as if the calendar year ended on the day before the expatriation. 2904. Information reporting (a) In general Not later than 12 months after the date of the enactment of this section, the Secretary shall by regulation require the reporting of any information concerning the net value of assets appropriate to enforce the tax imposed by this chapter. (b) Method of reporting The Secretary shall, where appropriate, require the reporting made under subsection (a) to be made as a part of existing income reporting requirements (including requirements under chapter 4 (relating to taxes to enforce reporting on certain foreign accounts)). (c) Responsibility for reporting The Secretary may impose reporting obligations by reference to the ownership, control, management, claim to income from, or other relationship to assets and liabilities for purposes of administering the tax imposed by this section and may impose such obligations on financial institutions, business entities, or other persons, including requiring business entities to provide estimates of the value of the entity itself. 2905. Enforcement The Secretary shall annually