1990
HR 3590 EAS/PP
(B) I
NCLUSION
OF
FOREIGN
CORPORA
-
1
TIONS
.--For purposes of subparagraph (A), in
2
applying subsections (a) and (b) of section 52 of
3
such Code to this section, section 1563 of such
4
Code shall be applied without regard to sub-
5
section (b)(2)(C) thereof.
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(d) U
NITED
S
TATES
H
EALTH
R
ISK
.--For purposes of
7
this section, the term ``United States health risk'' means
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the health risk of any individual who is--
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(1) a United States citizen,
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(2) a resident of the United States (within the
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meaning of section 7701(b)(1)(A) of the Internal Rev-
12
enue Code of 1986), or
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(3) located in the United States, with respect to
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the period such individual is so located.
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(e) T
HIRD
P
ARTY
A
DMINISTRATION
A
GREEMENT
16
F
EES
.--For purposes of this section, the term ``third party
17
administration agreement fees'' means, with respect to any
18
covered entity, amounts received from an employer which
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are in excess of payments made by such covered entity for
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health benefits under an arrangement under which such em-
21
ployer self-insures the United States health risk of its em-
22
ployees.
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(f) T
AX
T
REATMENT OF
F
EES
.--The fees imposed by
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this section--
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