controlled group
(3) Special rule for members of controlled group In the case of any controlled group— (A) all insurance companies which are members of such group shall be treated as 1 company for purposes of this subsection, and (B) the amount to which paragraph (1) applies shall be allocated among such companies in such manner as the Secretary may prescribe. For purposes of the preceding sentence, the term “controlled group” means any controlled group of corporations as defined in section 1563(a); except that subsections (a)(4) and (b)(2)(D) of section 1563 shall not apply, and subsection (b)(2)(C) of section 1563 shall not apply to the extent it excludes a foreign corporation to which section 842 applies.