50 percent
(III)For purposes of subclause (I), the term “qualified life insurance company” means any company which would be a life insurance company as defined inif unearned premiums were not taken into account under subsections (a)(2) and (c)(2) of section 816. (E)For purposes of this paragraph— (i)The term “non-owner employee” means any employee who does not own, at any time during the taxable year, more than 5 percent in value of the outstanding stock of the taxpayer. For purposes of the preceding sentence,shall apply, except that “5 percent” shall be substituted for “50 percent” in section 318(a)(2)(C).