liquidation, put, call, or conversion right
(2) Liquidation, etc. rights (A) In general The term “liquidation, put, call, or conversion right” means any liquidation, put, call, or conversion right, or any similar right, the exercise or nonexercise of which affects the value of the transferred interest. (B) Exception for fixed rights (i) In general The term “liquidation, put, call, or conversion right” does not include any right which must be exercised at a specific time and at a specific amount. (ii) Treatment of certain rights If a right is assumed to be exercised in a particular manner under subsection (a)(3)(B), such right shall be treated as so exercised for purposes of clause (i). (C) Exception for certain rights to convert The term “liquidation, put, call, or conversion right” does not include any right which— (i) is a right to convert into a fixed number (or a fixed percentage) of shares of the same class of stock in a corporation as the transferred stock in such corporation under subsection (a)(1) (or stock which would be of the same class but for nonlapsing differences in voting power), (ii) is nonlapsing, (iii) is subject to proportionate adjustments for splits, combinations, reclassifications, and similar changes in the capital stock, and (iv) is subject to adjustments similar to the adjustments under subsection (d) for accumulated but unpaid distributions. A rule similar to the rule of the preceding sentence shall apply for partnerships.