### Question
What does qualified insurance branch mean?


### Answer
**Qualified insurance branch** has the following meaning in *26 U.S.C. § 964*:

> any branch of a controlled foreign corporation which is licensed and predominantly engaged on a permanent basis in the active conduct of an insurance business in a foreign country if—


(A) separate books and accounts are maintained for such branch,


(B) the principal place of business of such branch is in such foreign country,


(C) such branch would be taxable under subchapter L if it were a separate domestic corporation, and


(D) an election under this paragraph applies to such branch

#### Citation:
  - *26 U.S.C. § 964*
  - Heading: **Subtitle A-Income Taxes > CHAPTER 1-NORMAL TAXES AND SURTAXES > Subchapter N-Tax Based on Income From Sources Within or Without the United States > PART III-INCOME FROM SOURCES WITHOUT THE UNITED STATES > Subpart F-Controlled Foreign Corporations**

