financial services income

(i)Except as otherwise provided in this subparagraph, the term “financial services income” means any income which is received or accrued by any person predominantly engaged in the active conduct of a banking, insurance, financing, or similar business, and which is— (I)described in clause (ii), or (II)passive income (determined without regard to subparagraph (B)(iii)(II)). (ii)Income is described in this clause if such income is— (I)derived in the active conduct of a banking, financing, or similar business, (II)derived from the investment by an insurance company of its unearned premiums or reserves ordinary and necessary for the proper conduct of its insurance business, or (III)of a kind which would be insurance income as defined indetermined without regard to those provisions of paragraph (1)(A) of such section which limit insurance income to income from countries other than the country in which the corporation was created or organized. (E)


26 USC § 904(d)(2)(D)(i)

Scoping language

in this subparagraph
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