### Question
How does NORMAL TAXES AND SURTAXES define qualifying insurance company branch?


### Answer
Under *26 U.S.C. § 953*, **qualifying insurance company branch** is defined as:

> a qualified business unit (within the meaning of section 989(a)) of a controlled foreign corporation if—


(A) such unit is licensed, authorized, or regulated by the applicable insurance regulatory body for its home country to sell insurance, reinsurance, or annuity contracts to persons other than related persons (within the meaning of section 954(d)(3)) in such home country, and


(B) such controlled foreign corporation is a qualifying insurance company, determined under paragraph (3) as if such unit were a qualifying insurance company branch

#### Citation:
  - *26 U.S.C. § 953*
  - 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**

