(A) In general This subsection shall apply to every insurance company other than life (including interinsurers and reciprocal underwriters) if
(i) the net written premiums (or, if greater, direct written premiums) for the taxable year do not exceed $1,200,000, and
(ii) such company elects the application of this subsection for such taxable year.
The election under clause (ii) shall apply to the taxable year for which made and for all subsequent taxable years for which the requirements of clause (i) are met. Such an election, once made, may be revoked only with the consent of the Secretary.
(B) Controlled group rules
(i) In general For purposes of subparagraph (A), in determining whether any company is described in clause (i) of subparagraph (A), such company shall be treated as receiving during the taxable year amounts described in such clause (i) which are received during such year by all other companies which are members of the same controlled group as the insurance company for which the determination is being made.
(ii) Controlled group For purposes of clause (i), the term controlled group means any controlled group of corporations (as defined in section
1563 (a)); except that
(I) more than 50 percent shall be substituted for at least 80 percent each place it appears in section
1563 (a), and
(II) subsections (a)(4) and (b)(2)(D) of section 1563 shall not apply.