(2) with respect to such an applicable taxpayer, and (C) proper adjustments shall be made in the amount of gain or loss subsequently realized for gain or loss taken into account under subparagraph (A). (4) Delay in reporting requirement If— (A) a notice is received by an applicable entity under subsection (b)(2)(A) or paragraph (2) for any taxable year of the entity with respect to any person holding directly (or indirectly through 1 or more nontradable interests) a nontradable interest in such entity, and (B) no notice is in effect with respect to such person or any other person for the preceding taxable year, then, except as provided by the Secretary, such notice shall be treated as first taking effect for purposes of this subsection, section 351(h), and section 1031(i) for the taxable year immediately following the taxable year in which the notice is received. This paragraph shall not apply to a notice described in subparagraph (A) received by an applicable entity from a person who was a significant owner (within the meaning of subsection (b)(4)) of such entity (or any predecessor entity) on the date of the enactment of this part. (5) Secretarial authority In prescribing rules for the application of this subsection, the Secretary may provide— (A) simplified methods for applicable entities to meet the requirements of this subsection, including the aggregation of gains and losses where appropriate, (B) rules for determining a holder's share of amounts required to be reported by an applicable entity under paragraph (1), and (C) any rules necessary to prevent the avoidance of the purposes of this section, including through the delay in the reporting requirement under paragraph (4). (d) Definitions and rules relating to application of section For purposes of this part— (1) Applicable entity The term applicable entity means any— (A) partnership, (B) S corporation, or (C) other pass-through entity specified in regulations or guidance prescribed by the Secretary. (2) Election to treat entity as applicable taxpayer