dividend equivalent
(2) Dividend equivalent For purposes of this subsection, the term “dividend equivalent” means— (A) any substitute dividend made pursuant to a securities lending or a sale-repurchase transaction that (directly or indirectly) is contingent upon, or determined by reference to, the payment of a dividend from sources within the United States, (B) any payment made pursuant to a specified notional principal contract that (directly or indirectly) is contingent upon, or determined by reference to, the payment of a dividend from sources within the United States, and (C) any other payment determined by the Secretary to be substantially similar to a payment described in subparagraph (A) or (B).