UNDERWRITING INCOME.

SEC. 1036. UNDERWRITING INCOME. (a) Treatment as Income From Sources Within the United States.— Section 861(a) (relating to gross income from sources within the United States) is amended by adding the following new paragraph: “(7) Amounts received as underwriting income (as defined in section 832(b)(3)) derived from the insurance of United States risks (as defined in section 953(a)).”. (b) Treatment as Foreign Source Income.— Section 862(a) (relating to gross income from sources without the United States) is amended by adding the following new paragraph: “(7) Underwriting income other than that derived from sources within the United States as provided in section 861(a)(7).”. (c) Effective Date.— The amendments made by tills section shall apply to taxable years beginning after December 31, 1976,