(as defined in section 954) of a controlled foreign corporation. (2) Active foreign market income includes certain income The term active foreign market income shall include— (A) if the controlled foreign corporation or a qualified business unit of the corporation is an eligible controlled foreign corporation (as defined in section 954(c)), any item of income of the corporation or unit which is qualified banking or financing income (as so defined), (B) if the controlled foreign corporation or a qualified business unit of the corporation is a qualifying insurance company (as defined in section 954(d)) or a qualifying insurance company branch (as so defined), any item of income of the corporation or unit which is qualified insurance income (as so defined), (C) any item of income which is rents or royalties derived from the ownership and operation (including leasing) of real or personal property which is not treated as passive income under section 954(a)(2)(A), and (D) in the case of a regular dealer in property which is property described in section 954(a)(1)(B), forward contracts, option contracts, or similar financial instruments (including notional principal contracts and all instruments referenced to commodities), any item of income from any transaction (including hedging transactions and transactions involving physical settlement) entered into in the ordinary course of such dealer's trade or business as such a dealer. (3) Gain or loss from sales of stock in other CFCs If a controlled foreign corporation sells, exchanges, or otherwise disposes of stock in another controlled foreign corporation which is a related person to the selling corporation— (A) gain from such sale, exchange, or disposition shall be treated as active foreign market income to the extent that such gain would have been excluded from gross income under section 1203 if the selling corporation were a United States shareholder in the other controlled foreign corporation, and (B) loss from such sale, exchange, or disposition shall not be allowed