§ 806. Small life insurance company deduction
(a)
Small life insurance company deduction
(1)
In general
For purposes of section
804, the small life insurance company deduction for any taxable year is 60 percent of so much of the tentative LICTI for such taxable year as does not exceed $3,000,000.
(2)
Phaseout between $3,000,000 and $15,000,000
The amount of the small life insurance company deduction determined under paragraph (1) for any taxable year shall be reduced (but not below zero) by 15 percent of so much of the tentative LICTI for such taxable year as exceeds $3,000,000.
(3)
Small life insurance company deduction not allowable to company with assets of $500,000,000 or more
(A)
In general
The small life insurance company deduction shall not be allowed for any taxable year to any life insurance company which, at the close of such taxable year, has assets equal to or greater than $500,000,000.
(b)
Tentative LICTI
For purposes of this part—
(1)
In general
The term “tentative LICTI” means life insurance company taxable income determined without regard to the small life insurance company deduction.
(2)
Exclusion of items attributable to noninsurance businesses
The amount of the tentative LICTI for any taxable year shall be determined without regard to all items attributable to noninsurance businesses.
(3)
Noninsurance business
(A)
In general
The term “noninsurance business” means any activity which is not an insurance business.
(B)
Certain activities treated as insurance businesses
For purposes of subparagraph (A), any activity which is not an insurance business shall be treated as an insurance business if—
(c)
Special rule for controlled groups
(1)
Small life insurance company deduction determined on controlled group basis
For purposes of subsection (a)—
(2)
Nonlife insurance members included for asset test
For purposes of subsection (a)(3), all members of the same controlled group (whether or not life insurance companies) shall be treated as 1 company.
(4)
Adjustments to prevent excess detriment or benefit
Under regulations prescribed by the Secretary, proper adjustments shall be made in the application of this subsection to prevent any excess detriment or benefit (whether from year-to-year or otherwise) arising from the application of this subsection.