### Question
How is the "derivative" defined?


### Answer
The term **derivative** is defined in *26 U.S.C. § 59A* as follows -

> any contract (including any option, forward contract, futures contract, short position, swap, or similar contract) the value of which, or any payment or other transfer with respect to which, is (directly or indirectly) determined by reference to one or more of the following:


(i) Any share of stock in a corporation

#### Citation:
  - *26 U.S.C. § 59A*
  - Heading: **Subtitle A-Income Taxes > CHAPTER 1-NORMAL TAXES AND SURTAXES > Subchapter A-Determination of Tax Liability > PART VII-BASE EROSION AND ANTI-ABUSE TAX**

