total insurance liabilities
(2) Required U.S. assets (A) In general For purposes of paragraph (1), the required United States assets of any foreign company for any taxable year is an amount equal to the product of— (i) the mean of such foreign company’s total insurance liabilities on United States business, and (ii) the domestic asset/liability percentage applicable to such foreign company for such year. (B) Total insurance liabilities For purposes of this paragraph— (i) Companies taxable under part I In the case of a company taxable under part I, the term “total insurance liabilities” means the sum of the total reserves (as defined in section 816(c) ) plus (to the extent not included in total reserves) the items referred to in paragraphs (3), (4), (5), and (6) of section 807(c). (ii) Companies taxable under part II In the case of a company taxable under part II, the term “total insurance liabilities” means the sum of unearned premiums and unpaid losses. (C) Domestic asset/liability percentage The domestic asset/liability percentage applicable for purposes of subparagraph (A)(ii) to any foreign company for any taxable year is a percentage determined by the Secretary on the basis of a ratio— (i) the numerator of which is the mean of the assets of domestic insurance companies taxable under the same part of this subchapter as such foreign company, and (ii) the denominator of which is the mean of the total insurance liabilities of the same companies.