(c)(2)) would otherwise have been in effect, gain or loss described in subparagraph (A) which would have been reported if such notice had been filed. (4) Significant owner For purposes of this subsection— (A) In general The term significant owner means, with respect to any applicable entity, an applicable taxpayer who, at any time during the applicable taxpayer's taxable year— (i) is a 5-percent owner with respect to such entity, or (ii) holds nontradable interests in such entity with an aggregate applicable value of greater than $50,000,000. (B) 5-percent owner (i) In general The term 5-percent owner mean, with respect to any applicable entity, an applicable taxpayer who owns (or is considered as owning within the meaning of section 318) at least 5 percent of— (I) in the case of a corporation, the stock (by vote or value) in such corporation, or (II) in the case of an applicable entity other than a corporation, the capital or profits interests in such entity. (ii) Constructive ownership rules For purposes of this subparagraph— (I) subparagraph (C) of section 318(a)(2) shall be applied by substituting 5 percent for 50 percent , and (II) in the case of an applicable entity which is not a corporation, ownership in such entity shall be determined in accordance with regulations prescribed by the Secretary which shall be based on principles similar to the principles of section 318 (as modified by subclause (I)). (c) Additional entity reporting requirements (1) In general Except as provided in paragraph (4), an applicable entity for any taxable year shall, at such times and in such manner as the Secretary shall prescribe, report to each applicable taxpayer with respect to which a notice is in effect under subsection (b)(2)(A) or paragraph (2)— (A) in the case of tradable covered assets held by such entity, such taxpayer's share of— (i) gain or loss determined by the entity under rules similar to the rules under section 491, and (ii) proper adjustments shall be made in the amount of gain or loss subsequently realized