(A) with respect to any tradable covered asset by reason of the taxpayer holding a nontradable interest in an applicable entity— (i) the applicable entity's adjusted basis of such asset (solely for purposes of computing the taxpayer's share of such adjusted basis), and (ii) the taxpayer's adjusted basis of such nontradable interest, shall each be appropriately adjusted to reflect gain or loss so taken into account. Such rules shall also provide proper adjustments to adjusted bases where such ownership is held through tiered entities. (C) Special rules for deferral recapture amount (i) Holding period Except as prescribed by the Secretary, if an applicable taxpayer takes into account gain under subparagraph (A) for any taxable year from an applicable transfer by such applicable entity of a nontradable covered asset, the taxpayer's holding period with respect to such asset for purposes of computing the deferral recapture amount under section 492 shall be the shorter of— (I) the entity's holding period in such asset, or (II) the taxpayer's holding period in such entity. (ii) Other rules The Secretary shall prescribe rules for purposes of this section— (I) for the treatment of fragmented holding periods, (II) for the determination of holding periods in the case of tiered structures, and (III) to prevent the shifting of any deferral recapture amount between taxpayers holding ownership interests in an applicable entity. (D) Taxpayers failing to file notice Under rules required by the Secretary, if a taxpayer fails to file a notice with any applicable entity as required under paragraph (2)(A), such taxpayer shall take into account, in computing the taxpayer's tax liability under this chapter for any taxable year for which such notice (or a related notice under subsection (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,