(3) Definitions For purposes of this subsection— (A) Preferred stock The term “preferred stock” means stock which is limited and preferred as to dividends and does not participate in corporate growth to any significant extent. Stock shall not be treated as participating in corporate growth to any significant extent unless there is a real and meaningful likelihood of the shareholder actually participating in the earnings and growth of the corporation. If there is not a real and meaningful likelihood that dividends beyond any limitation or preference will actually be paid, the possibility of such payments will be disregarded in determining whether stock is limited and preferred as to dividends. (B) Related person A person shall be treated as related to another person if they bear a relationship to such other person described in section 267(b) or 707(b).
26 USC § 351(g)(3)
None identified. Default scope is assumed to be the entire title.