of this subsection, rules similar to the rules of section 958 shall apply. (c) Special rule for income derived in the active conduct of banking, financing, or similar businesses (1) In general For purposes of subsection (a)(1), passive income shall not include qualified banking or financing income of an eligible controlled foreign corporation. (2) Eligible controlled foreign corporation For purposes of this subsection, the term eligible controlled foreign corporation means any controlled foreign corporation if— (A) more than 80 percent of the gross income of the controlled foreign corporation is derived directly from the active and regular conduct of a lending, finance, or financial services business from transactions with customers which are located outside the United States and are not related persons, or (B) it is a regulated financial institution. (3) Qualified banking or financing income For purposes of this subsection— (A) In general The term qualified banking or financing income means income of an eligible controlled foreign corporation which— (i) is derived in the active conduct of a banking, financing, or similar business by such eligible controlled foreign corporation, (ii) is derived from one or more transactions— (I) with customers located in a country other than the United States, and (II) substantially all of the activities in connection with which are conducted directly by the corporation in its home country, and (iii) is treated as earned by such corporation in its home country for purposes of such country's tax laws. (B) Income derived from customers to include certain investment income For purposes of subparagraph (A), in the case of a regulated financial institution, income derived from customers includes income derived from— (i) reserves that are required to be held pursuant to banking regulations, (ii) deposits placed with the central bank (or equivalent thereof) in the corporation’s home country, and (iii) investments in debt instruments issued by the home country. (C) Substantial activity