“ SHORT PARTY- The term `short party' means, with respect to any underlying security of any notional principal contract, any party to the contract which is not a long party with respect to such underlying security. ”

“ PREVENTION OF OVER-WITHHOLDING- In the case of any chain of dividend equivalents one or more of which is subject to tax under subsection (a) or section 881, the Secretary may reduce such tax, but only to the extent that the taxpayer can establish that such tax has been paid with respect to another dividend equivalent in such chain, or is not otherwise due, or as the Secretary determines is appropriate to address the role of financial intermediaries in such chain. ”