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).

Source

26 USC § 871(m)(2)


Scoping language

For purposes of this subsection
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