payments with respect to such debt instrument are determined by reference to the value of a nonfunctional currency (as so defined). (d) Treatment of American Depository Receipts and similar instruments Except as otherwise provided by the Secretary, for purposes of this subchapter, American depository receipts (and similar instruments) with respect to shares of stock in foreign corporations shall be treated as shares of stock in such foreign corporations. . (b) Information reporting with respect to controlled foreign corporations Section 6038(a)(1)(B) of such Code is amended by inserting and transactions which are covered transactions for purposes of section 4475 by reason of the application of section 4475(h)(1) to such corporation before the semicolon at the end. (c) Conforming amendment The table of subchapters for chapter 36 of such Code is amended by inserting after the item relating to subchapter B the following new item: Subchapter C. Tax on trading transactions. . (d) Effective date The amendments made by this section shall apply to transactions after December 31, 2023.