Covered asset acquisition
For purposes of this section, the term “covered asset acquisition” means—
(A)#
a qualified stock purchase (as defined in section 338(d)(3)) to which section 338(a) applies,
(B)#
any transaction which—
(i) is treated as an acquisition of assets for purposes of this chapter, and
(ii) is treated as the acquisition of stock of a corporation (or is disregarded) for purposes of the foreign income taxes of the relevant jurisdiction,
(B)(i)#
is treated as an acquisition of assets for purposes of this chapter, and
(B)(ii)#
is treated as the acquisition of stock of a corporation (or is disregarded) for purposes of the foreign income taxes of the relevant jurisdiction,
(C)#
any acquisition of an interest in a partnership which has an election in effect under section 754, and
(D)#
to the extent provided by the Secretary, any other similar transaction.