equity interest
(2) Amount of increase (A) In general The amount of the increase determined under this paragraph shall be the excess (if any) of— (i) the value of the qualified payments payable during the period beginning on the date of the transfer under subsection (a)(1) and ending on the date of the taxable event determined as if— (I) all such payments were paid on the date payment was due, and (II) all such payments were reinvested by the transferor as of the date of payment at a yield equal to the discount rate used in determining the value of the applicable retained interest described in subsection (a)(1), over (ii) the value of such payments paid during such period computed under clause (i) on the basis of the time when such payments were actually paid. (B) Limitation on amount of increase (i) In general The amount of the increase under subparagraph (A) shall not exceed the applicable percentage of the excess (if any) of— (I) the value (determined as of the date of the taxable event) of all equity interests in the entity which are junior to the applicable retained interest, over (II) the value of such interests (determined as of the date of the transfer to which subsection (a)(1) applied). (ii) Applicable percentage For purposes of clause (i), the applicable percentage is the percentage determined by dividing— (I) the number of shares in the corporation held (as of the date of the taxable event) by the transferor which are applicable retained interests of the same class, by (II) the total number of shares in such corporation (as of such date) which are of the same class as the class described in subclause (I). A similar percentage shall be determined in the case of interests in a partnership. (iii) Definition For purposes of this subparagraph, the term “equity interest” has the meaning given such term by subsection (a)(4)(B). (C) Grace period For purposes of subparagraph (A), any payment of any distribution during the 4-year period beginning on its due date shall be treated as having been made on such due date.