described in such paragraph is set forth in a schedule for such taxable year filed in the manner provided by the Secretary, and (B) the failure to meet such requirement is due to reasonable cause and not due to willful neglect. (2) Imposition of tax on failures If paragraph (1) applies to catastrophic risk transfer company for any taxable year, there is hereby imposed on such company a tax in an amount equal to the excess of— (A) the gross income of such company which is not derived from sources referred to in subsection (b)(2), over (B) one-ninth of the gross income of such company which is derived from such sources. (e) Definitions For purposes of this part— (1) Catastrophic risk (A) In general The term catastrophic risk means a risk of loss which has a low likelihood of occurring but which will be large in amount. (B) Special rules For purposes of subparagraph (A)— (i) in the case of direct insurance, a risk of loss shall not be treated as large in amount unless such loss would exceed $25,000,000 if it occurs, and (ii) in the case of mortality risk, the risk of loss transferred may be taken into account under subparagraph (A) only if it involves a pool of mortality or longevity risks. (2) Investments and income (A) Qualified investment The term qualified investment means— (i) cash, (ii) interests in money market funds, and (iii) investment-grade debt securities and funds primarily holding such debt securities. (B) Investment income The term investment income means interest that is accrued or received on, distributions in connection with, or proceeds from the disposition of, qualified investments. (3) Regulated insurance company The term regulated insurance company means any company which is licensed to engage in the business of insurance in a State and which is subject to State law which regulates insurance (within the meaning of section 514(b)(2) of the Employee Retirement Income Security Act of 1974, as in effect on the date of the enactment of this section). (4) Related person A person shall be treated as