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 paragraphs (2) and (3) of section 1504(b)) which is predominantly engaged in the active conduct of a banking, insurance, financing, or similar business. In determining whether such a group is so engaged, there shall be taken into account only the income of members of the group that are— (I) United States corporations, or (II) controlled foreign corporations in which such United States corporations own, directly or indirectly, at least 80 percent of the total voting power and value of the stock. (iii) Pass-thru entities The Secretary shall by regulation specify for purposes of this subparagraph the treatment of financial services income received or accrued by partnerships and by other pass-thru entities which are not members of a financial services group. (D) Financial services income (i) In general Except as otherwise provided in this subparagraph, the term financial services income means any income which is received or accrued by any person predominantly engaged in the active conduct of a banking, insurance, financing, or similar business, and which is— (I) described in clause (ii), or (II) United States taxpayer passive income (determined without regard to subparagraph (A)(ii)). (ii) General description of financial services income Income is described in this clause if such income is— (I) derived in the active conduct of a banking, financing, or similar business, (II) derived from the investment by an insurance company of its unearned premiums or reserves ordinary and necessary for the proper conduct of its insurance business, or (III) of a kind which would be insurance income as defined in section 955(a). (E) High-taxed income The term high-taxed income means any income which (but for this subparagraph) would be passive category income if the sum of— (i) the