distribution right
(1) Distribution right (A) In general The term “distribution right” means— (i) a right to distributions from a corporation with respect to its stock, and (ii) a right to distributions from a partnership with respect to a partner’s interest in the partnership. (B) Exceptions The term “distribution right” does not include— (i) a right to distributions with respect to any interest which is junior to the rights of the transferred interest, (ii) any liquidation, put, call, or conversion right, or (iii) any right to receive any guaranteed payment described in section 707(c) of a fixed amount.