### Question
How is the term qualifying insurance company defined?


### Answer
The term **qualifying insurance company** is defined in *26 U.S.C. § 954* as the following:

> any entity which—


(I) is subject to regulation as an insurance company under the laws of its country of incorporation,


(II) realizes at least 50 percent of its net written premiums from the insurance or reinsurance of risks located within the country in which such entity is created or organized, and


(III) is engaged in the active conduct of an insurance business and would be subject to tax under subchapter L if it were a domestic corporation

#### Citation:
  - *26 U.S.C. § 954*
  - 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**

