(within the meaning of section 451(b)), other financial or accounting statements, insurance valuations, or similar documents, and (2) requiring persons required to file returns under paragraph (1) to furnish statements to such other persons as the Secretary determines appropriate which contain all or a portion of the information contained in such return. (j) Regulations The Secretary shall issue such regulations or other guidance as may be necessary or appropriate to carry out the purposes this section and sections 25F and 36C, including regulations or other guidance to— (1) require reporting of basis and estimated value of assets, aggregated by asset class or otherwise, held by the applicable taxpayer, and liabilities of the applicable taxpayer, as of the close of the taxable year, in such manner as the Secretary may provide, (2) discourage applicable taxpayers from inappropriately converting assets into assets which are non-readily tradable assets, (3) treat assets held directly or indirectly by the applicable taxpayer as held by the applicable taxpayer, (4) in such circumstances as the Secretary determines there is a reasonable risk of an intent to avoid tax, treat assets owned or controlled by persons related to the applicable taxpayer as owned by the applicable taxpayer, (5) provide for the application of such sections with respect to married individuals, including rules with respect to— (A) individuals whose marital or joint return filing status changes, and (B) the transfer of an individual’s minimum tax account balance to the individual’s spouse or otherwise upon the death of such individual, (6) provide that the tax imposed under this section shall not be taken into account in determining the amount of any required payment of estimated tax or in satisfying the safe harbor to avoid a penalty for the underpayment of estimated tax, and (7) if the Secretary determines appropriate to carry out the purposes of this section, provide for the separate application of such sections with respect to different