(2) Control For purposes of paragraph (1)— (A) Corporations In the case of a corporation, the term “control” means the holding of at least 50 percent (by vote or value) of the stock of the corporation. (B) Partnerships In the case of a partnership, the term “control” means— (i) the holding of at least 50 percent of the capital or profits interests in the partnership, or (ii) in the case of a limited partnership, the holding of any interest as a general partner. (C) Applicable family member For purposes of this subsection, the term “applicable family member” includes any lineal descendant of any parent of the transferor or the transferor’s spouse.
26 USC § 2701(b)(2)
None identified. Default scope is assumed to be the entire title.