term "debt instrument" shall not include any annuity contract to which section 72 applies and which— (i) depends (in whole or in substantial part) on the life expectancy of 1 or more individuals, or (ii) is issued by an insurance company subject to tax under subchapter L (or by an entity described in

(a) Purpose and scope. This section sets forth information reporting requirements under section 6038B concerning certain transfers of property to foreign corporations. Paragraph (b) of this section provides general rules explaining when and how to carry out the reporting required under section 6038B with respect to the transfers to foreign corporations. Paragraph (c) of this section and

(a) Insurance income (1) In generalFor purposes of section 952(a)(1), the term "insurance income" means any income which— (A) is attributable to the issuing (or reinsuring) of an insurance or annuity contract, and

valuation misstatement under chapter 1 (within the meaning of section 6662(e)), a substantial estate or gift tax valuation understatement (within the meaning of section 6662(g)), or a gross valuation misstatement (within the meaning of

Paragraph (2) shall not apply to a corporation, trust, or association which was considered to be a real estate investment trust for any taxable year beginning on or before October 4, 1976. (b) Change of accounting period without approvalNotwithstanding section 442, an entity which has not engaged in any active trade or business

thereof) during the period beginning on the date of issuance of such obligation and ending on the date of maturity. (b) DefinitionsFor purposes of this section— (1) Registration-required obligation (A) In generalThe term "registration-required obligation" has the same meaning as when used in