beginning before the applicable date (as defined in section 300 of the Infrastructure 2.0 Act ). (B) 25-Percent owner For purposes of this paragraph, the term 25-percent owner means a controlled foreign corporation which owns directly 25 percent or more of the capital or profits interest in a partnership. For purposes of the preceding sentence, if a controlled foreign corporation is a shareholder or partner of a corporation or a partnership, the controlled foreign corporation shall be treated as owning directly its proportionate share of any capital or profits interest in any partnership held directly or indirectly by such corporation or partnership. If a controlled foreign corporation is treated as owning a capital or profits interest in a partnership under constructive ownership rules similar to the rules of section 958(b), the controlled foreign corporation shall be treated as owning such interest directly for purposes of this subparagraph. (c) Treatment of insurance income (1) In general Except as otherwise provided in this subsection, the term active foreign market income shall not include the insurance income (as defined in section 955(a)) of a controlled foreign corporation. (2) Active foreign market income includes exempt insurance income The term active foreign market income shall include exempt insurance income (as defined in section 955(c)) shall be treated as active foreign market income. (d) Treatment of income from property used, consumed, or disposed of in the United States For purposes of subsection (a)(2)(A)— (1) In general The term active foreign market income shall not include income derived in connection with property which is sold, exchanged, or otherwise disposed of to any person if it was reasonable for the controlled foreign corporation (or a related person) to expect that— (A) such property would be used, consumed, or disposed of in the United States, or (B) such property would be used in the manufacture or production of, or as a component part in, other property which would be used,