(6) Home country For purposes of this subsection, except as provided in regulations— (A) Controlled foreign corporation The term “home country” means, with respect to a controlled foreign corporation, the country in which such corporation is created or organized. (B) Qualified business unit The term “home country” means, with respect to a qualified business unit (as defined in section 989(a) ), the country in which the principal office of such unit is located and in which such unit is licensed, authorized, or regulated by the applicable insurance regulatory body to sell insurance, reinsurance, or annuity contracts to persons other than related persons (as defined in section 954(d)(3)) in such country.
26 USC § 953(e)(6)
None identified. Default scope is assumed to be the entire title.