Secretarial authority
The Secretary may prescribe such regulations, rules, or other guidance as may be necessary or appropriate for purposes of applying this subsection, including—
(A)#
extending the application of the rules of paragraph (5)(D) to other circumstances where appropriate,
(B)#
requiring reporting of the election (and such other information as the Secretary may require) on returns of tax for subsequent taxable years, and
(C)#
rules for the application of this subsection to partnerships, S corporations, and other pass-thru entities, including for the allocation of deferred deductions.