TREATMENT OF INSURANCE COMPANIES UNDER CHAIN DEFICIT RULE.

SEC. 6131. TREATMENT OF INSURANCE COMPANIES UNDER CHAIN DEFICIT RULE. (a) In General.—Subparagraph (B) of section 952(c)(1) of the 1986 Code is amended by adding at the end thereof the following new clause: “(vii) Special rules for insurance income.— “(I) In general.—An election may be made under this clause to have section 953(a) applied for purposes of this title without regard to the same country exception under paragraph (I)(A) thereof. Such election, once made, may be revoked only with the consent of the Secretary. “(II) Special rules for affiliated groups.—In the case of an affiliated group of corporations (within the meaning of section 1504 but without regard to section 1504(b)(3) and by substituting ‘more than 50 percent’ for ‘at least 80 percent’ each place it appears), no election may be made under subclause (D for any controlled foreign corporation unless such election is made for all other controlled foreign corporations who are members of such group and who were created or organized under the laws of the same country as such controlled foreign corporation. For purposes of clause (v), in determining whether any controlled corporation described in the preceding sentence is a qualified insurance company, all such corporations shall be treated as 1 corporation.” (b) Effective Date.—The amendment made by this section shall take effect as if included in the amendments made by section 1221(f) of the Reform Act.