in effect, and any entity receiving such notice shall treat such taxpayer as an applicable taxpayer, for the period specified by the Secretary. The Secretary may require additional reporting by such entities for purposes of carrying out this clause. (B) Requirement only applies if applicable taxpayer is significant owner An applicable entity shall be required to report under subparagraph (A) to another applicable entity only if the applicable taxpayer is a significant owner (within the meaning of subsection (b)(4)) of such other entity, determined only by taking into account interests in such other entity which such applicable taxpayer holds by reason of its ownership interests in the entity otherwise required to report and such other ownership interests in such other entity as the Secretary may require to be taken into account to prevent the avoidance of the purposes of this part. (3) Special rules for disregarded nonrecognition events In the case of an applicable transfer of a nontradable covered asset of an applicable entity which is a disregarded nonrecognition event— (A) notwithstanding any other provision of this title, gain or loss shall be recognized and taken into account in the taxable year in which the transfer occurs as if the entity had sold the nontradable covered asset for its fair market value immediately before such transfer (or such other value as is determined as of such time under rules prescribed by the Secretary), (B) such entity shall report the amount of gain or loss required to be taken into account under subparagraph (A) to— (i) each applicable taxpayer with respect to which a notice is in effect which such entity has received under subsection (b)(1), and (ii) each other applicable entity from which it has received a notice under paragraph (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