qualifying insurance corporation

(1) In general The term “qualifying insurance corporation” means, with respect to any taxable year, a foreign corporation— (A) which would be subject to tax under subchapter L if such corporation were a domestic corporation, and (B) the applicable insurance liabilities of which constitute more than 25 percent of its total assets, determined on the basis of such liabilities and assets as reported on the corporation’s applicable financial statement for the last year ending with or within the taxable year.

Source

26 USC § 1297(f)(1)

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Scoping language

None identified, default scope is assumed to be the parent (subpart D) of this section.

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