determined under paragraph (1) for the taxable year, and (II) the number of taxable years beginning after the date of the sale or disposition and before the last day of the applicable period. (B) Applicable period For purposes of this paragraph, the applicable period is the 10-year period beginning on the later of— (i) the date the taxpayer acquired the applicable partnership interest, or (ii) the last date described in paragraph (1)(B)(ii) on which there was an increase in the amount of the taxpayers applicable percentage of the aggregate invested capital of all partners of the partnership. (6) Multiple interests If at any time during a taxable year a taxpayer holds directly or indirectly more than 1 applicable partnership interest in a single partnership, such interests shall be treated as 1 applicable partnership interest for purposes of applying this subsection. (d) Related person For purposes of this section, a person shall be treated as related to another person if the relationship between such persons would be described in section 267(b) or 707(b). (e) Reporting A partnership shall report to the Secretary, and include with the information required to be furnished under section 6031(b) to each partner, the amount of the partner’s deemed compensation amount for the taxable year, if any. A similar rule applies to any entity that receives a report of a deemed compensation amount for the taxable year. (f) Regulations The Secretary shall issue such regulations or other guidance as necessary to carry out this section, including regulations— (1) to prevent the abuse of the purposes of this section, including through— (A) the allocation of income to tax indifferent parties, or (B) a reduction or increase in the invested capital of any partner (including attempts to undervalue or overvalue property), (2) which provide for the application of the rules of subsection (c) to applicable financial instruments and contracts and to entities other than partnerships, (3) which provide in appropriate circumstances for