(5) Special rules for application of paragraph (2) in the case of short sales For purposes of paragraph (2)— (A) In general The term “interest” includes any amount paid or incurred— (i) by any person making a short sale in connection with personal property used in such short sale, or (ii) by any other person for the use of any collateral with respect to such short sale. (B) Exception where no return on cash collateral If— (i) the taxpayer provides cash as collateral for any short sale, and (ii) the taxpayer receives no material earnings on such cash during the period of the sale, subparagraph (A)(i) shall not apply to such short sale.
26 USC § 265(a)(5)
None identified. Default scope is assumed to be the entire title.