dividend
(2)For purposes of this section, the term “dividend” does not include any distribution or payment— (A)to the extent provided in regulations prescribed by the Secretary— (i)by a foreign corporation, or (ii)to a foreign corporation, a nonresident alien, or a partnership not engaged in a trade or business in the United States and composed in whole or in part of nonresident aliens, or (B)except to the extent otherwise provided in regulations prescribed by the Secretary, to any person described in section 6049(b)(4).