(F) premiums from a contract shall not be taken into account for purposes of paragraph (2)(B) or (3) if such contract reinsures a contract issued or reinsured by a related person (as defined in section 954(b)). (8) Coordination with section 956(a) (A) In general In determining insurance income for purposes of section 956(a), exempt insurance income shall not include income derived from exempt contracts which cover risks other than applicable home country risks. (B) Applicable home country risks For purposes of subparagraph (A), the term applicable home country risks means risks in connection with property in, liability arising out of activity in, or the lives or health of residents of, the home country of the qualifying insurance company or qualifying insurance company branch, as the case may be, issuing or reinsuring the contract covering the risks. (9) Regulations The Secretary shall prescribe such regulations as may be necessary or appropriate to carry out the purposes of this subsection and section 954(d). (10) Cross reference For treatment of certain investment income derived by qualifying insurance companies, see section 954(d). 956. Special rule for certain captive insurance companies (a) Treatment as controlled foreign corporations and United States shareholders (1) In general For purposes only of taking into account related person insurance income— (A) the term United States shareholder means, with respect to any foreign corporation, a United States person (as defined in section 957(c)) who owns (within the meaning of section 958(a)) any stock of the foreign corporation, (B) the term controlled foreign corporation has the meaning given to such term by section 957(a) determined by substituting 25 percent or more for more than 50 percent , and (C) the pro rata share referred to in section 951(a)(1) shall be determined under paragraph (5) of this subsection. (2) Related person insurance income For purposes of this subsection, the term related person insurance income means any insurance income (within the