gross insurance income

(3) De minimis, etc., rules For purposes of subsection (a) and section 953 — (A) De minimis rule If the sum of foreign base company income (determined without regard to paragraph (5)) and the gross insurance income for the taxable year is less than the lesser of— (i) 5 percent of gross income, or (ii) $1,000,000, no part of the gross income for the taxable year shall be treated as foreign base company income or insurance income. (B) Foreign base company income and insurance income in excess of 70 percent of gross income If the sum of the foreign base company income (determined without regard to paragraph (5)) and the gross insurance income for the taxable year exceeds 70 percent of gross income, the entire gross income for the taxable year shall, subject to the provisions of paragraphs (4) and (5), be treated as foreign base company income or insurance income (whichever is appropriate). (C) Gross insurance income For purposes of subparagraphs (A) and (B), the term “gross insurance income” means any item of gross income taken into account in determining insurance income under section 953.

Source

26 USC § 954(b)(3)

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Scoping language

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

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