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 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, (4) which provide for the application of this section in cases of tiered structures or entities, (5) which provide guidance with respect to forgiveness of any loan described in subsection (b)(4)(B), and (6) which provide rules for transfers or liquidations of applicable partnership interests by gift, inheritance, substituted basis transactions, and other transactions in which income is not recognized at the time of the transaction. . (b) Conforming amendments (1) (A) Part IV of subchapter O of chapter 1 of the Internal Revenue Code of 1986 is amended by striking section 1061. (B) The table of sections for part IV of subchapter O of chapter 1 of such Code is amended by striking the item relating to section 1061. (2) The table of parts for subchapter P of such Code is amended by adding at the end the following new item: Part VII—Treatment of certain partnership interests received in connection with performance of services . (c) Effective date The amendments made by this section shall apply to taxable years of a taxpayer beginning after date of enactment of this Act, with or within which ends the taxable year of a partnership which begins after such date.