Sec. 805. Basic interest rate. Sec. 806. Foreign financial intermediation services. 801. Determination of financial intermediation services amount (a) Financial Intermediation Services For purposes of this subtitle— (1) In general The term financial intermediation services means the sum of— (A) explicitly charged fees for financial intermediation services, and (B) implicitly charged fees for financial intermediation services. (2) Explicitly charged fees for financial intermediation services The term explicitly charged fees for financial intermediation services includes— (A) brokerage fees, (B) explicitly stated banking, loan origination, processing, documentation, credit check fees, or other similar fees, (C) safe-deposit box fees, (D) insurance premiums, to the extent such premiums are not allocable to the investment account of the underlying insurance policy, (E) trustees’ fees, and (F) other financial services fees (including mutual fund management, sales, and exit fees). (3) Implicitly charged fees for financial intermediation services (A) In general The term implicitly charged fees for financial intermediation services includes the gross imputed amount in relation to any underlying interest-bearing investment, account, or debt. (B) Gross imputed amount For purposes of subparagraph (A), the term gross imputed amount means— (i) with respect to any underlying interest-bearing investment or account, the product of— (I) the excess (if any) of the basic interest rate (as defined in section 805) over the rate paid on such investment, and (II) the amount of the investment or account, and (ii) with respect to any underlying interest-bearing debt, the product of— (I) the excess (if any) of the rate paid on such debt over the basic interest rate (as defined in section 805), and (II) the amount of the debt. (b) Seller of Financial Intermediation Services For purposes of section 103(a), the seller of financial intermediation services shall be— (1) in the case of explicitly charged fees for financial intermediation