2 years

(i)The term “qualified preferred dividend” means any fixed dividend payable with respect to any share of stock which— (I)provides for fixed preferred dividends payable not less frequently than annually, and (II)is not in arrears as to dividends at the time the taxpayer acquires the stock. (ii)In determining the holding period for purposes of subparagraph (A)(ii), subsection (d)(3) shall be applied by substituting “5 years” for “2 years”. (f)

Source

26 USC § 1059(e)(3)(C)(i)


Scoping language

For purposes of this paragraph
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