not, in and of itself, be deemed to provide a substantial benefit. (E) Other definitions For purposes of this paragraph— (i) Control The term control has the meaning given in section 800.208 of title 31, Code of Federal Regulations (as in effect on the date of enactment of the Protecting American Advanced Manufacturing Act ). (ii) Foreign adversary The term foreign adversary has the meaning given the term covered nation in section 4872(d)(2) of title 10, United States Code. (3) Administration The Secretary may issue such guidance as is necessary to carry out the purposes of this subsection, including establishment of rules for— (A) implementation of paragraph (2)(C)(i) for determination of whether the percentage requirements with respect to outstanding equity interests have been satisfied in the case of an entity for which the stock of such entity is traded on an established securities market in the United States or any foreign country, and (B) preventing entities from evading, circumventing, or abusing the application of the requirements under this subsection. . (b) Effective date The amendment made by this section shall apply to taxable years beginning after the date of enactment of this Act.