applicable retained interest

(1) In general The term “applicable retained interest” means any interest in an entity with respect to which there is— (A) a distribution right, but only if, immediately before the transfer described in subsection (a)(1), the transferor and applicable family members hold (after application of subsection (e)(3)) control of the entity, or (B) a liquidation, put, call, or conversion right.


26 USC § 2701(b)(1)

Scoping language

For purposes of this section
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