covered asset acquisition
(2) Covered asset acquisition For purposes of this section, the term “covered asset acquisition” means— (A) a qualified stock purchase (as defined in section 338(d)(3) ) to which section 338(a) applies, (B) any transaction which— (i) is treated as an acquisition of assets for purposes of this chapter, and (ii) is treated as the acquisition of stock of a corporation (or is disregarded) for purposes of the foreign income taxes of the relevant jurisdiction, (C) any acquisition of an interest in a partnership which has an election in effect under section 754, and (D) to the extent provided by the Secretary, any other similar transaction.