(d) of section 904 is amended to read as follows: (d) Separate application of section with respect to certain categories of income (1) In general The provisions of subsections (a), (b), and (c) and sections 907 and 960 shall be applied separately with respect to— (A) amounts included under section 951(a) which are attributable to active foreign market income (as defined in section 953), (B) passive category income, and (C) income other than income described in either of the preceding subparagraphs. (2) Definitions and special rules (A) Passive category income (i) In general The term passive category income means— (I) United States taxpayer passive income described in subparagraph (B), and (II) income which is included in gross income of the taxpayer under section 951(a)(1) to the extent such income is attributable to passive income (as defined in section 954(a)). (ii) Exception for high-taxed income Passive category income shall not include any high-taxed income. (iii) Clarification of application of section 864(d)(6) In determining whether any income is passive category income, the rules of section 864(d)(6) shall apply only in the case of income of a controlled foreign corporation. (B) United States taxpayer passive income United States taxpayer passive income described in this subparagraph is income received or accrued by the taxpayer which is of a kind that would be passive income as defined under section 954(a) if such taxpayer were a controlled foreign corporation. (C) Treatment of financial services income and companies (i) In general Financial services income which is not active foreign market category income shall be treated as income described in paragraph (1)(C) in the case of— (I) a member of a financial services group, and (II) any other person if such person is predominantly engaged in the active conduct of a banking, insurance, financing, or similar business. (ii) Financial services group The term financial services group means any affiliated group (as defined in section 1504(a) without regard to