Which criterion does not qualify a foreign corporation for the benefits of a comprehensive income tax treaty in the U.S.?

The correct answer highlights that the characteristic of allowing for the purchase of preferred stock does not play a role in determining a foreign corporation's eligibility for benefits under a comprehensive income tax treaty with the U.S. Such treaties typically focus on the residency of the corporation, the nature of its income, and whether it meets specific criteria set out in the treaty.

Incorporation in a U.S. possession is a relevant criterion, as it establishes a certain level of connection to U.S. tax jurisdiction, which can impact the applicability of the treaty. Similarly, a corporation that is explicitly qualified for benefits under a comprehensive tax treaty is essential since treaties are designed to confer benefits to certain entities based on their adherence to established guidelines.

Additionally, the requirement that stock for which dividends are paid be readily tradable addresses the liquidity and market presence of the investment, which can play a role in certain tax treaty benefits. However, the specific provision concerning preferred stock does not align with these qualifying criteria. Thus, it stands out as irrelevant to determining eligibility for treaty benefits.